State v. B.L., 2023AP8, 4/11/23, District 1 (1-judge opinion, ineligible for publication); case activity “Barry” appealed an order terminating his parental rights to his 4 1/2-year-old daughter, Alice. He argued that the circuit court erred in admitting his criminal history during the grounds phase and erred in finding that it was in Alice’s best interest… Read more
E. Procedure
State v. N.H., 2022AP1945, District 1, 03/14/2023, (one-judge decision, not eligible for publication) case activity This case presents a relatively straightforward application of how Bangert applies to termination of parental rights pleas. As noted by the decision, however, the Wisconsin Supreme Court is currently considering a more nuanced version of the issue in State v. A.G… Read more
State v. Y.P.V., 2022AP1935-36, 3/21/23, District 1 (1-judge opinion, ineligible for publication); case activity The court of appeals reversed and remanded this TPR for two reasons. First, the mom made a prima facie case that her “no contest” plea to grounds was not knowing, intelligent, and voluntary because, during the plea colloquy, the circuit court… Read more
Kenosha County v. A.C.S., 2022AP1821-1825, 2/15/23, District 2 (one judge decision; ineligible for publication); case activity Here’s a fact pattern one hopes doesn’t come up too often. The county sought the termination of “Anna’s” parental rights to five children. It then moved for summary judgment on the grounds that she’d been convicted of a serious… Read more
Portage County DH & HS v. C.S., 2022AP1090, District 4, 02/23/2023, (one-judge decision, ineligible for publication) case activity In what appears to be a first, the court of appeals addresses a grant of partial summary judgment against a parent specifically related to whether the county made a “reasonable effort” to provide services pursuant to a… Read more
R.G. v. S.P., 2022AP1876, District 4, 02/16/2023 (one judge opinion; ineligible for publication); case activity R.G. filed a petition to voluntarily terminate his parental rights to a non-marital child that he had not seen in over seven years. The circuit court dismissed his petition for lack of jurisdiction. R.G. pursued an appeal pro se, arguing… Read more
Brown County DHHS v. T.R., 2022AP1094, District 3, 1/20/23 (one-judge decision; ineligible for publication); case activity In a TPR proceeding a motion for summary judgment may be filed any time before trial, as prescribed in § 48.297(1) and (2), and is not governed by the time limit for summary judgment motions prescribed in § 802.08(1)… Read more
State v. O.F., 2022AP1703, District 1, 01/18/2023 (one-judge decision; ineligible for publication); case activity Ultimately, the issue addressed by the court of appeals is whether O.F. received ineffective assistance of counsel where trial counsel was alleged to have “violated his duty of confidentiality and loyalty” to his client. O.F.’s claims were based on multiple statements… Read more