1. Best interests of the child

State v. S.O., 2024AP1350, 10/8/24, District I (one-judge decision; ineligible for publication); case activity S.O. (“Sarah”) challenges the order terminating her parental rights to her son, “Daniel,” arguing that the circuit court erroneously exercised its discretion at disposition when it failed to explicitly consider Daniel’s wishes. Daniel was removed from his parents’ care shortly after… Read more

State v. H.C., 2023AP1950, 3/5/24, District I (one-judge decision; ineligible for publication); petition for review granted 9/11/24 case activity In an interesting decision that seems almost guaranteed to invite review by SCOW, COA departs from the plain language of the statute and reads a burden of proof requirement into the TPR dispositional procedure. Before we get… Read more

Sheboygan County DHHS v. J.L., 2023AP1884, 1/3/24, District 2 (one-judge decision; ineligible for publication); case activity In yet another appeal of the circuit court’s discretionary decision to terminate a parent’s rights, COA easily rejects J.L.’s invitation to reweigh the evidence. J.L.’s appellate challenge is narrow. Having stipulated to grounds, his only argument on appeal is… Read more

Jefferson County DHS v. C.T.S., 2023AP1404, 11/2/23, District 4 (one-judge decision; ineligible for publication); case activity C.T.S. appeals an order terminating his parental rights to his son, K.S. The court of appeals affirms, holding the county adduced sufficient evidence of the continuing CHIPS ground and acted within its discretion in weighing the dispositional factors. As… Read more

State v. R.T., 2023AP1095 & 2023AP1096, District I, 9/12/23, 1-judge decision ineligible for publication; case activity (briefs not available) R.T. (“Richard”) pled no contest to grounds but disputed whether his parental rights should be terminated at disposition. Specifically, Richard argued that “there was no support in the record for the court’s finding that it was in… Read more

State of Wisconsin v. J.L.A., 2023AP424, District I, 6/27/23, 1-judge decision ineligible for publication; case activity (briefs not available) In a TPR appeal with a typically tragic fact pattern, the court of appeals defers to the circuit court’s decision to terminate “Julia’s” parental rights. Here, the State successfully obtained an order terminating Julia’s parental rights… 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