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1. Admission to grounds

State v. N.H., 2022AP1945, District 1, 03/14/2023, (one-judge decision, not eligible for publication) case activity This case presents a relatively straightforward application of how Bangert applies to termination of parental rights pleas. As noted by the decision, however, the Wisconsin Supreme Court is currently considering a more nuanced version of the issue in State v. A.G… Read more

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State v. Y.P.V., 2022AP1935-36, 3/21/23, District 1 (1-judge opinion, ineligible for publication); case activity The court of appeals reversed and remanded this TPR for two reasons. First, the mom made a prima facie case that her “no contest” plea to grounds was not knowing, intelligent, and voluntary because, during the plea colloquy, the circuit court… Read more

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SCOW to address plea withdrawal in TPR cases

State v. A.G., 2022AP652, two petitions for review of unpublished court of appeals opinions granted 10/11/22; reversed, 2023 WI 61; case activity Issues for review: From the State’s petition: Whether A.G., the father who lost his parental rights, knowingly, intelligently, and voluntarily pled “no contest” to grounds for termination of his rights. From the GAL’s petition… Read more

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Parent’s challenge to TPR plea rejected

State v. M.J.C., 2022AP779, District 1, 10/4/22 (one-judge decision; ineligible for publication); case activity The court of appeals rejects M.J.C. attempt to withdraw his no contest plea to the petition to terminate his parental rights to J.C. To withdraw his plea, M.J.C. has to point to a defect in the court’s plea colloquy and assert… Read more

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State v. M.B., 2022AP89, District 1, 7/19/22 (one-judge decision; ineligible for publication); case activity M.B. entered a no contest plea to failing to assume parental responsibility and to her daughter being in continuing need of protection or services. During the plea colloquy, the circuit court suggested she had the “same trial rights” at the dispositional… Read more

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State v. A.G., 2022AP652, 7/12/22, District 1 (1-judge opinion, ineligible for publication); petitions for review granted, 10/11/22, reversed, 2023 WI 61; case activity District 1 means business. Not long ago, it reversed an order denying A.G.’s claim that his no-contest plea to grounds for a TPR was not knowing, intelligent, and voluntary because the circuit court… Read more

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State v. V.R., 2020AP798 & 2020799, 1/26/21, Distrct 1 (1-judge opinion; ineligible for publication); case activity This is an appeal from an order terminating V.R.’s parental rights. The court of appeals rejected a no-merit report because the record revealed that neither defense counsel nor the circuit court had discussed the meaning of a “substantial parental… Read more

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State v. J.T., 2020AP1151, 1/5/21, District 1 (1-judge opinion, ineligible for publication); case activity E.W. was placed in foster care shortly after birth. Her dad, J.T., was incarcerated then. He remained so a year later when the State filed a TPR petition against him on the grounds that he failed to establish a substantial relationship… Read more

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