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TPR – Underlying CHIPS Order: Implied “Specific Services”

Dane Co. DHS v. Samuel W., 2009AP2606 , District 4, 10/14/10

court of appeals decision (1-judge, not for publication); for Samuel W.: Eileen A. Hirsch, SPD, Madison Appellate

Under Sheboygan County DHHS v. Tanya M.B., 2010 WI 55, although a CHIPS dispositional order must set forth the “specific services” to be provided, it may do so implicitly. Applying that holding here, the court of appeals concludes that the conditions for return in the CHIPS order were not so “generic” they didn’t imply the ordered services: “… although the conditions in the present case are less detailed than those found inTanya M.B., they nevertheless establish the services, however minimal, that the Department was to provide. We therefore conclude that in light of the supreme court’s opinion in Tanya M.B., services were specified as required by WIS. STAT. § 48.355(2)(b)1,” ¶27.

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