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D. Grounds, Sec. 48.415

N.D. v. E.S., 2022AP1084, District 2, 01/25/23 (one-judge decision; ineligible for publication); case activity Nancy (N.D.) petitioned to terminate Ed’s (E.D.’s) parental rights on the grounds that he abandoned their daughter, Kim. See Wis. Stat. § 48.415(1). At trial, Ed asserted a “good cause” defense that Nancy prevented him from having contact with Kim, and… Read more

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Rusk County DHHS v. R.S., 2022AP1530, District 3, 1/20/23 (one-judge decision; ineligible for publication); case activity R.S. (“Ruth”) argues that at the trial on the County’s petition to terminate her parental rights, the County Department of Health and Human Services didn’t prove it made reasonable efforts to provide the services ordered in the original CHIPS… Read more

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L.E.H. v. R.E.M., 2022AP713-715, 11/22/11, District 1; (1-judge opinion, ineligible for publication); case activity “Luke” and “Rebecca” had 3 children together. After their relationship ended, Rebecca struggled with addiction and was charged with a number of crimes. Luke married and successfully petitioned to terminate Rebecca’s parental rights.  Rebecca appealed the TPR arguing the circuit court… Read more

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COA again rejects challenges to TPR

Portage County DH & HS v. S.Z. & C.Z., 2022AP1352-1355, 11/17/2022, District 4 (one-judge decision; ineligible for publication); case activity This case is the companion of C.Z. & S.Z., decided two weeks ago. C.Z. is the father of the four children at issue; S.Z., the appellant here, is the mother. The opinion here is pretty… Read more

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COA rejects challenges to TPR

Portage County DH & HS v. C.Z & S.Z., 2022AP1249-1252; 11/3/2022, District 4 (one-judge decision; ineligible for publication); case activity C.Z. appeals the termination of his parental rights to his four children. The court of appeals affirms. The opinion is a long one, but much of it is dedicated to explaining things like the court’s… Read more

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State v. A.A.L., 2022AP1074, 10/11/22, District 1, (1-judge opinion, ineligible for publication); case activity  A parent’s failure to meet the conditions for the return of her child due to her incarceration is not a constitutional basis for finding her an unfit parent during the grounds phase of a TPR proceeding. Kenosha County DHS v. Jodie… Read more

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COA upholds TPR

Juneau County D.H.S. v. R.M., 2022AP1260, 9/29/22, District 4 (one-judge decision; ineligible for publication); case activity R.M. appeals the termination of her parental rights to her son, M.M. R.M. first argues there was insufficient evidence for jury’s unfitness findings as to both continuing CHIPS and failure to assume parental responsibility. The court of appeals recites… Read more

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TPR order affirmed

State v. J.W., 2022AP1338, District 1, 10/4/22 (one-judge decision; ineligible for publication); case activity J.W.’s challenges the sufficiency of the evidence at both the grounds and dispositional phases of the proceeding that terminated his parental rights to J.W., Jr. The court of appeals rejects his arguments. The TPR petition alleged continuing CHIPS under § 48.415(2)… Read more

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