Oneida Co. DSS v. Nicole W., 2007 WI 30, affirming unpublished decision
Issue: Whether partial summary judgment against Nicole was properly granted under Wis. Stat. § 48.415(10) (prior involuntary TPR within 3 years) when the prior termination order did not state the explicit § 48.415 ground relied on.
¶2 We conclude that Wis. Stat. § 48.415(10)(b) does not require proof of which § 48.415 ground was relied upon for a prior termination of parental rights because the phrase, “on one or more of the grounds specified in this section,” in § 48.415(10)(b) refers to proving only that the prior termination was an involuntary termination. …
¶19 Wisconsin Stat. § 48.415(10)(b) does not require proof of which of the available 12 grounds set out in § 48.415 was the basis for the involuntary termination because the phrase, “on one or more of the grounds specified in this section,” is meant as only a general directive that assures the termination of rights was involuntary. In regard to the sufficiency of a prior order that can be used as grounds under § 48.415(10), there is no need for the order to specify which ground was employed, as any of the grounds set out in § 48.415 is sufficient to satisfy the requirement of paragraph (10)(b).  …
 Of course the issue may be different if the termination of Nicole’s parental rights to Rockey were being appealed. In that case, the reviewing court could be asked to ascertain whether sufficient proof was admitted by the circuit court to support the court’s determination that a specific ground was proved by clear and convincing evidence. However, an appeal of the termination of Nicole’s parental rights to Rockey is not before us.