E. Procedure

State v. T.N., 2014AP2407 & 2014AP2408, District 4, 9/10/15 (one-judge decision; ineligible for publication); case activity The circuit court properly entered a default judgment against T.N. in his TPR proceeding when, despite the court’s warnings and admonitions, T.N. failed to appear at a scheduled court appearance. At T.N.’s initial appearance the court told him to… Read more

State v. M.H., 2015AP711, District 1, 9/1/15 (one-judge decision; ineligible for publication); case activity The circuit court properly exercised its discretion in concluding that M.H. had not shown that her termination of parental rights proceeding should be reopened based on her “excusable neglect” in failing to appear at the dispositional hearing. When M.H. failed to appear… Read more

State v. T.P., 2015AP857, District 1, 8/18/15 (one-judge decision; ineligible for publication); case activity Recently enacted statutes allow a circuit court to presume that a parent in a TPR proceeding has waived the right to counsel if, after being ordered to appear in court, the parent fails to do so and the court finds that failure egregious… Read more

Dane County DHS v. D.M., 2014AP2291, District 4, 7/30/15 (one-judge decision; ineligible for publication); case activity Trial counsel wasn’t ineffective for arguing § 48.415(6) is unconstitutional as applied to D.M., as she fails to demonstrate that the County made it impossible for her to satisfy the conditions for return of her child, D.L. ¶12    … Read more

Kenosha County DHS v. A.C., 2015AP151, District 2, 7/22/15 (one-judge decision; ineligible for publication); case activity Trial counsel for A.C. in his TPR proceeding wasn’t ineffective for failing to tell A.C. that his incarceration was not enough by itself to terminate his parental rights or for failing to challenge the TPR proceeding on the basis that the grounds were unconstitutional as… Read more

State v. Jodie A., 2015AP46 & 2015AP47, District 1, 7/7/15 (one-judge decision; ineligible for publication); case activity The trial court that accepted Jodie A.’s admission as to grounds to terminate her parental rights failed to comply with two of the requirements for accepting an admission set forth in § 48.422(7)—namely, the court didn’t inquire about adoptive resources and didn’t require… Read more

State v. Amelia A., 2015AP630 & 2015AP631, District 1, 6/9/15 (one-judge decision; ineligible for publication); case activity While the order extending the placement of Amelia’s children outside of her home did not specifically recite the conditions she needed to meet for the return of her children, the extension order specifically incorporated by reference the original CHIPS order, which did… Read more