On Point blog, page 2 of 8

COA affirms default finding in TPR due to single missed court date

State v. A.L., 2025AP177, 4/22/25, District I (1-judge decision, ineligible for publication); case activity

Despite the respondent’s claim that she was never given notice of the time for a jury status hearing, COA affirms the circuit court’s default finding.

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COA affirms suppression ruling based on illegible license plate

State v. Natalie S. Lozano, 2024AP1540-CR & 2024AP1541-CR, 4/9/25, District II (1-judge decision, ineligible for publication); case activity

In yet another appeal hinging on the requirement that a license plate be “legible,” COA affirms based on its deference to the circuit court’s factual findings.

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COA rejects sufficiency challenge to grounds and finds that court did not err in terminating parental rights

State v. R.J.S., 2024AP2186, 2/7/25, District I (1-judge decision, ineligible for publication); case activity

COA rejects R.J.S.’s challenges to the sufficiency of the evidence and applies a well-settled standard of review to uphold the circuit court’s discretionary termination order.

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COA holds that trial court properly removed adversary counsel in CHIPS case; reverses order reducing lawyer’s fee

Richland County DH&HS v. D.M.K., 2022AP2190, District IV, 11/14/24 (one-judge decision; ineligible for publication); case activity

In a somewhat rare CHIPS appeal, COA upholds the circuit court’s decision to remove adversary counsel but reverses the court’s order modifying that attorney’s request for fees.

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COA affirms competency ruling but reverses involuntary medication order

State v. M.M.K., 2024AP591-CR, 2024AP592-CR, 2024AP593-CR, 2024AP594-CR, 10/31/24, District IV(1-judge decision, ineligible for publication); case activity

In a case which continues a new trend in appeals of involuntary medication appeals, COA holds that while the circuit court correctly found M.M.K. incompetent, it failed to correctly apply Sell in ordering involuntary medication.

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TPR verdict and dispositional order affirmed

State v. T.H.-M., 2024AP1271-1273, District I, 10/29/24 (one-judge decision; ineligible for publication); case activity

In another dense and fact-specific opinion, COA holds that the evidence was sufficient to support a finding that the parent was unfit and rejects T.H.-M.’s argument that the circuit court improperly weighed the evidence at disposition.

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COA rejects argument that circuit court made incorrect dispositional findings and affirms

State v. C.M., 2024AP1416-1418, District I, 10/15/24 (one-judge decision; ineligible for publication); case activity

The parent’s challenge to the court’s discretionary termination decision goes nowhere given the standard of review.

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COA rejects challenges to TPR order and affirms

Waushara County DHS v. A.M.S., 2024AP730-733, District IV, 10/3/24 (one-judge decision; ineligible for publication); case activity

In a dense and fact-specific opinion, COA rejects A.M.S.’s attempts to argue that she was precluded from presenting relevant evidence at her TPR trial and affirms.

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COA rejects challenges to “abandonment” verdict in TPR involving allegations that mother withheld child’s location from father

A.M.D. v. G.R.B., Jr., 2024AP1071, District II, 9/18/24 (one-judge decision; ineligible for publication); case activity

G.R.B. (“Bartel”) appeals an order terminating his parental rights, raising a medley of challenges. Although COA acknowledges that its prior precedent sent “mixed signals” to litigants on at least one of the issues, it ultimately rejects all of G.R.B.’s arguments and affirms.

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COA affirms discretionary termination order under deferential standard of review

State v. T.L., 2024AP859-863, 8/1/24, District I (one-judge decision; ineligible for publication); case activity

In yet another TPR appeal challenging the circuit court’s discretionary termination order, COA affirms given the imposing standard of review.

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