Barron County DH & HS v. Q.B., 2023AP37, District 3, 6/13/23 (one-judge decision; ineligible for publication); case activity At the trial to terminate the parental rights of Q.B. (“Quan”) on grounds of continuing CHIPS and failure to assume parental responsibility, a substance abuse counselor referred to Quan having spent “quite a bit of time incarcerated… Read more
E. Procedure
Kenosha County Division of Child and Family Services v. D.R.-R., 2022AP1812, 06/01/23, District 2 (1-judge opinion, ineligible for publication); case activity In what should not be a shocking outcome, a mother’s failure to appear at a single pre-trial hearing is not “egregious” and does not support a default judgment on grounds. On Point has covered… Read more
Columbia County DHS v. K.D.K., 2022AP1835, 5/25/23, District 4 (1-judge opinion, ineligible for publication); case activity K.D.K. challenged an order terminating his parental rights to C.A.K. on 3 grounds: (1) the judge was not properly assigned to preside over his case; (2) the circuit court refused to give a special verdict question asking whether it… Read more
Winnebago County Department of Human Services v. N.J.D., 2023AP75, 05/03/2023 (District 2) (one-judge opinion, ineligible for publication); case activity Presented with two strong bases to reverse, the court of appeals picks one and holds that because the record “fails to demonstrate that N.D. waived his right to counsel,” the order terminating his parental rights to… Read more
Price County v. T.L., 2022AP1678, 4/25/2023, District 3 (1-judge opinion, ineligible for publication); case activity The law governing default TPRs is messy. Click here. This decision makes it messier. The County petitioned for a TPR arguing that “Tad” failed to assume parental responsibility for “Malcom.” The County served Tad with the summons, petition, and notice… Read more
Brown County Department of Human Services v. S.K., 2023 WI App 27; case activity A court has grounds to terminate parental rights under §48.415(9m) when the parent commits a “serious felony against a child.” Here, the circuit court found that grounds existed to terminate Stephanie’s parental rights to Robert because she had been convicted of … Read more
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
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
