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TPR – Self-Representation – Competency of Court – Delay in Disposition Hearing

Dane County DHS v. Susan P.S., 2006 WI App 100, PFR filed 5/15/06

Issue/Holding: Holding the dispositional hearing beyond the 45-day time limit set by § 48.424(4) did not deprive the trial court of competency to proceed, where good cause existed for continuance under § 48.315(2), namely that the respondent’s attorney was going to be out of town during a portion of the limitation period, and the trial court expressly found good cause to schedule the hearing after counsel’s return, ¶¶63-75.

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