State v. R.R.E
In State v. R.R.E., 162 Wis. 2d 698, 707, 470 N.W.2d 283 (1991) the supreme court considered whether R.R.E. was entitled to release from his not guilty by reason of mental disease or defect commitment when the circuit court failed to conduct his reexamination hearing within the statutory thirty-day time limit. See R.R.E., 162 Wis. 2d at 703.
The statute at issue, Wis. Stat. 51.20(16)(c) (1987-88), required that "a hearing shall be held on the petition within 30 days of receipt."
In holding that the time limits were directory, the R.R.E. court found that when creating the criminal commitment provisions, the legislature's objective-protecting the public from a dangerous individual-was the dominant consideration. See R.R.E., 162 Wis. 2d at 709, 712.