Sheboygan County v. N.A.L.

Summary

The Wisconsin Supreme Court held that constitutional due process does not require a circuit court to conduct a colloquy before accepting a stipulation to orders for involuntary commitment and medication under Wisconsin Statutes chapter 51. The court affirmed the court of appeals’ decision and did not address whether the respondent’s stipulation was otherwise knowing, intelligent, and voluntary. A concurrence questioned the lawfulness of stipulating to an involuntary commitment and emphasized the fundamental right to be free from physical restraint.

Holdings

1. The Fourteenth Amendment does not require a circuit court to conduct a colloquy before accepting an individual's stipulation to an order for commitment and involuntary medication in a chapter 51 proceeding.
2. The court did not decide whether N.A.L.'s stipulation was actually knowing, intelligent, and voluntary because N.A.L. did not otherwise challenge the validity of the stipulation.

Questions Presented

1. Whether the Fourteenth Amendment's Due Process Clause requires a Wisconsin circuit court to conduct a colloquy before accepting an individual's stipulation to an involuntary commitment order under Wisconsin Statutes chapter 51.
2. Whether the absence of such a colloquy is itself a structural constitutional error requiring reversal.

Disposition

affirmed