E. Procedure

State of Wisconsin v. M.S.H., 2023AP692, District I, 8/1/23, 1-judge decision ineligible for publication; case activity (briefs not available) A parent’s non-cooperation with an involuntary TPR leads to a default judgment and, despite some compelling arguments, COA rejects her invitation to reweigh the dispositional evidence and reverse the order terminating her parental rights. The State… Read more

State v. M.H., 2023AP732, District I, 7/11/23, 1-judge decision ineligible for publication; case activity (briefs not available) M.H. raises two challenges to a circuit court order terminating her parental rights. Under an exceedingly deferential standard of review, both claims fail. The State filed this TPR petition  in November of 2022. (¶3). At a hearing held… Read more

C.T.L. v. M.L.K., 2023AP402, District III, 7/11/23, 1-judge decision ineligible for publication; case activity (briefs not available) The court of appeals confronts two alleged errors stemming from M.L.K.’s TPR jury trial and affirms based on harmless error. This is an appeal of a comparatively rare privately-filed TPR action initiated by “Mary’s” paternal grandparents against Mary’s… Read more

State v. A.G., 2023 WI 61, 6/30/23, reversing an unpublished decision of the court of appeals; case activity (briefs not available) In a closely-watched appeal involving tricky questions regarding plea withdrawal in TPR cases, a fractured court agrees that the court of appeals got it wrong but fails to otherwise develop the law. (See our… Read more

State v. S.S., 2022AP1179 & 2022AP1180, District I, 6/7/23 (one-judge decision; ineligible for publication); case activity (briefs not available) In yet another TPR appeal with a parent alleging a defective plea colloquy, the court of appeals finds that the State proved the plea was knowing, intelligent, and voluntary at a postdisposition hearing. At the time… Read more

Barron County DH & HS v. Q.B., 2023AP37, District 3, 6/13/23 (one-judge decision; ineligible for publication); case activity At the trial to terminate the parental rights of Q.B. (“Quan”) on grounds of continuing CHIPS and failure to assume parental responsibility, a substance abuse counselor referred to Quan having spent “quite a bit of time incarcerated… Read more

Kenosha County Division of Child and Family Services v. D.R.-R., 2022AP1812, 06/01/23, District 2 (1-judge opinion, ineligible for publication); case activity In what should not be a shocking outcome, a mother’s failure to appear at a single pre-trial hearing is not “egregious” and does not support a default judgment on grounds. On Point has covered… Read more