State v. H.C., 2025 WI 20, 6/3/25, affirming an unpublished court of appeals decision; case activity In a decision that has been awaited by TPR practitioners, all seven justices affirm COA’s mandate, with five justices joining in a majority opinion which concludes there is no burden of proof applicable at a dispositional hearing. As we’ve… Read more
40. TPRs
State of Wisconsin v. F.S.-E., 2054AP10, District I, 5/20/25 (one-judge decision; ineligible for publication); case activity The COA rejects F.S.-E.’s claim that he is entitled to an evidentiary hearing to determine whether his no contest plea was knowingly, intelligently, and voluntarily made. It holds that there is no requirement that the circuit court pause after… Read more
Marathon County v. S.S., 2024AP1866, 5/8/25, District III (1-judge decision, ineligible for publication); case activity “Sean” appeals orders of the circuit court terminating his parental rights to his daughter, “Zoey,” and denying his motion for postdisposition relief. He argues that he was denied effective assistance of counsel in four respects during the grounds trial, and… Read more
State v. T.N., 2024AP1280, 4/22/25, District I (1-judge decision, ineligible for publication); case activity T.N. appeals, arguing that she received ineffective assistance of counsel when her attorney did not object to statements she contends are inadmissible hearsay. COA assumes without deciding that the statements were hearsay and affirms the circuit court’s orders, concluding there was… Read more
State v. A.L., 2025AP177, 4/22/25, District I (1-judge decision, ineligible for publication); case activity Despite the respondent’s claim that she was never given notice of the time for a jury status hearing, COA affirms the circuit court’s default finding. “Allie” received the usual warning given to parents in TPR matters–to appear at all future court… Read more
Waukesha County v. A.T., 2025AP167, 4/2/25, District II (1-judge decision, ineligible for publication); case activity “Amber” appeals from an order terminating her parental rights to her 6-year-old daughter, “Holly.” She argues the circuit court erroneously exercised its discretion at disposition. COA affirms under the deferential, erroneous exercise of discretion standard. Holly was removed from Amber’s… Read more
J.H. v. J.L.B., 2025AP85, 4/3/25, District IV (1-judge decision, ineligible for publication); case activity COA reviews the grant of summary judgment on abandonment and failure to assume parental rights de novo and concludes that there are issues of material fact as to each ground. The court therefore reverses and remands for a fact-finding hearing. The… Read more
Brown County v. N.H., 2024AP1991-1993, 4/2/25, District III (1-judge decision, ineligible for publication); case activity Although the County erred by listing the wrong date in a published notice, COA affirms given the court’s factual findings that the respondent was served by mail. In this TPR, the County was attempting to terminate the rights of a… Read more
