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4. Default judgment

State v. D.T., 2022AP909, 8/23/22, District 1 (oen-judge decision; ineligible for publication); case activity D.T. showed up late for his Zoom TPR trial. It had been set for 9:00; D.T. appeared at 11:00 and said he was having eye trouble that kept him from logging in. The circuit court defaulted him and declined to vacate… Read more

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Rock County Human. Servs. v. A.P., Appeal nos. 2022AP248-249; 7/14/22, District 4; (1-judge opinion, ineligible for publication); case activity This is one more in a long line of appellate decisions affirming a default finding of grounds for terminating a parent’s rights without a finding that the parent had behaved egregiously as required by Dane Cnty… Read more

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Dane County DHS v. A.D., 2022AP76 & 2022AP77, District 4, 3/31/22 (one-judge decision; ineligible for publication); case activity Another case showing that in TPR proceedings, “egregious” conduct is coming to mean “missing one hearing.” A.D. appeared at the first eight—count ’em: eight!—hearings at which he was ordered to appear. At the eighth hearing, the court allowed… Read more

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TPR default judgment challenge rejected

State v. L.M., 2021AP970, District 1, 9/8/21 (one-judge decision; ineligible for publication); case activity The circuit court properly exercised its discretion in denying L.M.’s motion to vacate the default judgment entered against her in this TPR case. L.M. failed to appear at the initial appearance, though she’d served by mail and told about the court… Read more

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State v. M.R.K., 2021AP141, District 1, 6/22/21 (one-judge decision; not recommended for publication); case activity The Latin word grex means “flock,” “herd,” or “group,” and is the root of several English words. Gregarious originally meant “tending to live in a flock, herd, or community rather than alone” but has become a synonym for “sociable.” Egregious… Read more

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State v. A.M.-C., 2021AP94 & 2021AP95, 3/30/21, District 1 (one-judge decision; ineligible for publication); case activity The state petitioned to terminate A.M.-C.’s rights to two of her children on failure-to-assume and continuing-CHIPS grounds. After being told (apparently via interpreter, as Spanish is her first language) that she had to attend all hearings, A.M.-C. moved to… Read more

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State v. L.C., 2020AP796, District 1, 7/28/20 (one-judge decision; ineligible for publication); case activity Whether to grant a default judgment in a TPR proceeding as a sanction for a parent’s egregious conduct is left to the circuit court’s discretion, and the circuit court properly exercised its discretion in defaulting L.C. After L.C. missed two depositions… Read more

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Waukesha County HHS v. S.S., 2020AP592, District 2, 6/10/20 (one-judge decision; ineligible for publication); case activity The circuit court properly exercised its discretion in ordering default judgment for S.S.’s egregious conduct of lying to the court to get her TPR trial adjourned. ¶13     As entry of a default judgment is a particularly harsh sanction… Read more

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