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E. Procedure

Manitowoc County Human Serv. Dep’t v. J.K., 2017AP2371, 2/21/18 (1-judge opinion, ineligible for publication); case activity If you handle TPR cases, this opinion is worth reading because the appellant raised creative arguments regarding, for example, the proper legal standard for summary judgment and a court’s ability to take judicial notice  of its own records. She… Read more

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TPR default judgment upheld

Kenosha County DHS v. V.J.G., 2017AP1150 & 2017AP1151, District 2, 12/27/17 (one-judge decision; ineligible for publication); case activity V.J.G.’s failed to appear at the pretrial and grounds trial in the TPR proceedings regarding his children. The circuit court then discharged V.J.G.’s lawyer, set a new evidentiary and dispostional hearing, and terminated V.J.G.’s parental rights. The court of… Read more

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Admission to TPR ground was valid

State v. S.N.N., 2016AP2102 & 2016AP2103, District 1, 12/12/17 (one-judge decision; ineligible for publication); case activity S.N.N. admitted the continuing CHIPS ground that was alleged in the TPR petition regarding her two children. The court of appeals rejects her claim that her admission was not knowing and voluntary. S.N.N. asserts she was not informed by her… Read more

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State v. R.G., 2017AP1078, District 1, 11/14/17 (one-judge decision; ineligible for publication); case activity After R.G.’s parental rights were terminated the child was removed from the care of D.L., the foster parent at the time of the TPR dispositional hearing and prospective adoptive parent, because D.L. was abusing the child. (¶¶5-6). A new disposition hearing isn’t… Read more

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Dane County DHS v. S.J., 2017AP1578-1580, 10/19/17, District 4 (1-judge opinion, ineligible for publication) case activity When an opinion starts by saying a mother answered more than 80 questions relating to her understanding of pleading “no contest” during the grounds phase of a TPR case and quotes the her lawyer as saying “she’s one of… Read more

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State v. M.P., 2016AP2104 & 2016AP2105, District 1, 10/17/17 (one-judge decision; ineligible for publication); case activity At the dispositional hearing on the petition to terminate M.P.’s parental rights to his two children the court heard evidence that the foster parents intended to allow M.P. to continue to have contact with the children if his parental rights were… Read more

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Directing TPR verdict was harmless error

State v. C.L.K., 2017AP1413 & 2017AP1414, District 1, 10/10/17 (one-judge decision; ineligible for publication), petition for review granted 3/14/18, reversed, 2019 WI 14; case activity The circuit court directed a verdict in favor of the state during the grounds phase of the TPR proceedings against C.L.K. without allowing him the opportunity to present evidence. The court of appeals… Read more

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Court of appeals upholds TPR summary judgment

J.N.W. v. J.R.P., 2017AP1390, 9/20/17, District 2 (one-judge decision, ineligible for publication); case activity Robert, the father of Jessica, appeals the termination of is parental rights. Specifically, he argues the trial court erred in granting summary judgment because there were genuine issues of material fact as to whether he failed to communicate with her for… Read more

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