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4. Default judgment

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State v. M.R.K., 2021AP141, District 1, 6/22/21 (one-judge decision; not recommended for publication); case activity The Latin word grex means “flock,” “herd,” or “group,” and is the root of several English words.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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State v. Z.J., 2019AP1623-1626, District 1, 11/19/19, (1-judge opinion, ineligible for publication); case activity All TPRs are sad. But this one really highlights the Catch 22 that poverty can create for a parent. Z.J., mother of 4, was struggling with drug and alcohol abuse. The State sought to terminate her parental rights for these and… Read more

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Default judgment in TPR affirmed

State v. C.M., 2019AP1483, District 1, 11/5/19 (one-judge decision; ineligible for publication); case activity The circuit court didn’t err in entering a default judgment against C.M. in her termination of parental rights proceeding.  C.M. failed to appear in person at the initial appearance, so the court called her on the phone, told her to talk… Read more

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