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Keywords

statutehearingtestimonycompliancehearsay

hearinghearsay

Related Cases

R-T-I-, Matter of

Facts

I.R.T. was first subject to emergency detention and involuntary commitment in 2017, with orders renewed over time. In September 2019, Waukesha County filed for an extension of his commitment after he failed to comply with treatment conditions since April 2019. At the recommitment hearing, I.R.T. did not appear, and the court relied on testimony from mental health professionals who noted his noncompliance and concerning behavior, including paranoia and hallucinations.

I.R.T. was first subject to an emergency detention and involuntary commitment and involuntary medication and treatment orders in 2017. These orders have since been renewed. On September 19, 2019, the County filed for an extension of I.R.T.'s commitment. The circuit court scheduled a hearing and appointed doctors to examine I.R.T. I.R.T. did not respond to the examiners' attempts to contact him, and they were forced to complete their evaluations based on the available records.

Issue

Did the circuit court err in extending I.R.T.'s involuntary commitment based on hearsay evidence and insufficient proof of dangerousness?

I.R.T. first argues that the circuit court's recommitment order erroneously relied on hearsay evidence. I.R.T. indicates that all the witnesses at the hearing testified to facts that they had no personal knowledge of; specifically, they described the events that led to I.R.T.'s initial commitment, and Weber testified about information from I.R.T.'s parents regarding his condition in 2019.

Rule

To involuntarily commit a person, the county must prove by clear and convincing evidence that the individual is mentally ill, a proper subject for treatment, and dangerous, as per Wis. Stat. 51.20.

To involuntarily commit a person, the county has the burden to prove by clear and convincing evidence that the person is (1) mentally ill, (2) a proper subject for treatment, and (3) dangerous. See 51.20(1)(a)(1) . -2 ., (13)(e); Langlade County v. D.J.W., 2020 WI 41, �3, 29, 391 Wis. 2d 231, 942 N.W.2d 277; Fond du Lac County v. Helen E.F., 2012 WI 50, �, 340 Wis. 2d 500, 814 N.W.2d 179.

Analysis

The court found that the circuit court did not err in relying on expert testimony regarding I.R.T.'s dangerousness, despite his claims of hearsay. The experts provided opinions based on I.R.T.'s treatment history and behavior, which indicated a substantial likelihood of dangerousness if treatment were withdrawn. The court emphasized that the statute allows for a determination of dangerousness based on treatment records and expert opinions.

The circuit court found that the evidence was clear and convincing that I.R.T. met the statutory requirements for extending the orders, granted the County's request, and entered orders for a one-year extension of involuntary commitment and involuntary medication and treatment.

Conclusion

The court affirmed the circuit court's order extending I.R.T.'s involuntary commitment, concluding that the evidence supported the findings of mental illness, proper subject for treatment, and dangerousness.

Accordingly, we affirm.

Who won?

Waukesha County prevailed in the case, as the court upheld the recommitment order based on clear evidence of I.R.T.'s mental illness and dangerousness.

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