In Gould v. American Family Mutual Ins. Co. (1996) 198 Wis. 2d 450 543 N.W.2d 282, the head nurse of the secured dementia unit of a residential health care center was injured when the defendant, a patient diagnosed with Alzheimer's disease who was "resistant to care, and occasionally combative," knocked her to the floor. (Id., 543 N.W.2d at p. 283.) The Wisconsin Supreme Court held that "an individual institutionalized with a mental disability, and who does not have the capacity to control or appreciate his or her conduct cannot be liable for injuries caused to caretakers who are employed for financial compensation." (Ibid.)