COA affirms TPR orders over sufficiency challenges
State v. M.G., 2025AP2883-2888, 5/15/26, District I (ineligible for publication); case activity
M.G. appeals orders terminating her parental rights to her six children on the basis that the circuit court erred when it found that the state had proven by clear and convincing evidence that child protective services made reasonable efforts and she failed to assume parental responsibility for the three youngest children. COA affirms.
“Molly” argues that the state failed to prove the department made reasonable efforts to help her follow all of the recommendations stemming from her psychological evaluation and provide her with medication management to fulfill the requirements of the CHIPS dispositional orders. (¶14). COA analyzes the evidence of the social worker’s actions and concludes that they were reasonable, as Molly found her own therapist, was often “hostile” and “very, very antagonistic and uncooperative” with the assigned worker, and refused medication management. (¶¶16-33).
As to failure to assume parental responsibility, Molly argues that the circuit court inappropriately distinguished the siblings into two groups based on how long they had been in out-of-home care and that she parented the children as much as she was allowed once they had been removed. (¶35). COA holds that the court did take into consideration the fact that the three children had been in out-of-home care for a significant part of their lives and acknowledged that served as an obstacle to Molly’s ability to parent, but that the evidence still demonstrated that Molly had neglected and exposed them to hazardous living conditions. (¶¶36-39). COA then details the neglect and hazards to which the children were exposed. (¶¶40-43).