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3. Claim/issue preclusion

Brown County DHS v. Terrance M., 2005 WI App 57 Issue/Holding: Because TPR cases are generally a subset of custody cases; and because claim preclusion is available as a means of discouraging groundless requests for modification of custody, both claim and issue preclusion “may also be applied when the facts so require” in TPRs, ¶¶8-9… Read more