Outagamie County v. Michael H.Annotate this Case
Outagamie County filed a petition for the involuntary commitment of Michael H. A jury found that Michael was mentally ill, was a proper subject for treatment, and was dangerous. Based on the verdict, the circuit court ordered Michael committed for treatment pursuant to Wisconsin’s involuntary commitment statute, Wis. Stat. 51.20. On appeal, Michael challenged the sufficiency of the evidence, specifically, the evidence that he was dangerous. The court of appeals affirmed, concluding that the evidence supported a finding of dangerousness under subsection (1)(a)(2)(a) relating to threats of suicide or self-harm. The Supreme Court affirmed, holding that credible evidence existed in the record supporting inferences that there was a substantial probability that Michael was dangerous to himself within the meaning of subsection (1)(a)(2)(1) based on threats of suicide or serious bodily harm, and (1)(a)(2)(c) based on impaired judgment, manifested by a pattern of recent acts.