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F. Fact-finding, Sec. 48.424

State v. J.C., 2017AP1783, District 1, 3/27/18 (one-judge decision; ineligible for publication); case activity J.C. pleaded no contest to the continuing CHIPS grounds alleged in the petition for termination of her parental rights. She later argued her plea wasn’t supported by sufficient evidence because, at the fact-finding hearing required under § 48.422(3) for no-contest pleas, there was no evidence the… Read More

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State v. D.C., 2017AP1635, 3/20/18, District 1 (one-judge opinion; ineligible for publication); case activity The circuit court terminated D.C.’s parental rights to his child, A.D.C.  On appeal, D.C. argued that the trial court (1) lost competency to proceed when it failed to conduct an initial appearance in the case, and (2) erred in denying his… Read More

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No erroneous exercise of discretion in TPR

State v. M.D.W., 2017AP1945 & 1946, 1/23/18, District 1 (one-judge decision; ineligible for publication); case activity M.D.W. appeals only the disposition in the TPR of her two children. She argues that the court erred in its consideration of the statutory factors. The court of appeals disagrees. There’s really not much to say about the opinion… Read More

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State v. M.K., 2017AP1952-1953, 12/27/17, District 1 (1-judge opinion, ineligible for publication); case activity The record for a termination of rights appeal is required by law to be confidential. Thus, in such a case the court of appeals must refer to the individuals involved by their initials, pseudonyms, or other appropriate designations. This rule balances… Read More

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Admission to TPR ground was valid

State v. S.N.N., 2016AP2102 & 2016AP2103, District 1, 12/12/17 (one-judge decision; ineligible for publication); case activity S.N.N. admitted the continuing CHIPS ground that was alleged in the TPR petition regarding her two children. The court of appeals rejects her claim that her admission was not knowing and voluntary. S.N.N. asserts she was not informed by her… Read More

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State v. M.P., 2016AP2104 & 2016AP2105, District 1, 10/17/17 (one-judge decision; ineligible for publication); case activity At the dispositional hearing on the petition to terminate M.P.’s parental rights to his two children the court heard evidence that the foster parents intended to allow M.P. to continue to have contact with the children if his parental rights were… Read More

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Evidence sufficient to establish TPR grounds

Racine County Human Services Dep’t v. C.C., 2017AP750, District 2, 10/11/17 (one-judge decision; ineligible for publication); case activity The evidence presented at the fact-finding hearing in C.C.’s TPR proceeding was sufficient to establish that she failed to assume parental responsibility under § 48.415(6). C.C. argues the evidence is insufficient to find that she failed to assume… Read More

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Directing TPR verdict was harmless error

State v. C.L.K., 2017AP1413 & 2017AP1414, District 1, 10/10/17 (one-judge decision; ineligible for publication), petition for review granted 3/14/18, reversed, 2019 WI 14; case activity The circuit court directed a verdict in favor of the state during the grounds phase of the TPR proceedings against C.L.K. without allowing him the opportunity to present evidence. The court of appeals… Read More

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