In Re Commitment of Combs

¶ 1. Christopher L. Combs, previously committed as a sexually violent person under Wis. Stat. ch. 980, appeals an order denying his petition for discharge. The circuit court held a probable cause hearing pursuant to Wis. Stat. § 980.09(2)(a) 1 and determined that the re-examination report opining that Combs was not a sexually violent person did not show probable cause to believe that he was no longer a sexually violent person. We agree with the circuit court that the opinion did not establish probable cause because it was based on historical facts, actuarial instruments, and theories of…