On Point blog, page 1 of 7
COA affirms TPR orders, concludes that trial counsel’s performance was not deficient and circuit court properly excluded evidence related to a younger child
State v. M.W., 2025AP2364 &2365 , 9/3/25, District I (ineligible for publication); case activity
M.W. appeals the orders terminating her parental rights to two of her children, “Liam” and “Karen,” and the order denying her motion for postdisposition relief. She argues that her trial counsel was ineffective when by failing object to multiple instances of hearsay, and her due process
rights were violated when the court ruled that she could not introduce evidence at trial that another child remained in her care. COA affirms.
COA rejects arguments that admission to grounds was not knowingly, intelligently and voluntarily entered, factual basis was insufficient, and trial counsel was ineffective in TPR appeal
Crawford County v. M.W., 2025AP302, 8/14/25, District IV (ineligible for publication); case activity
Despite concluding that M.W.’s plea colloquy was “lacking in certain respects” on the circuit court’s part, COA holds that the record supports the court’s postdisposition conclusion that M.W. knowingly, intelligently, and voluntarily entered his admission. COA also rejects M.W.’s arguments that the county failed to establish a factual basis and that trial counsel was ineffective.
COA rejects numerous IAC claims, affirms jury verdict in TPR appeal
Marathon County v. S.S., 2024AP1866, 5/8/25, District III (1-judge decision, ineligible for publication); case activity
“Sean” appeals orders of the circuit court terminating his parental rights to his daughter, “Zoey,” and denying his motion for postdisposition relief. He argues that he was denied effective assistance of counsel in four respects during the grounds trial, and that he was prejudiced by the individual and cumulative effects of counsel’s deficient performance. COA rejects Sean’s first two IAC claims and concludes that he failed to establish prejudice.
COA affirms TPR, holding parent failed to establish prejudice due to admission of “arguably inadmissible hearsay”
State v. T.N., 2024AP1280, 4/22/25, District I (1-judge decision, ineligible for publication); case activity
T.N. appeals, arguing that she received ineffective assistance of counsel when her attorney did not object to statements she contends are inadmissible hearsay. COA assumes without deciding that the statements were hearsay and affirms the circuit court’s orders, concluding there was no prejudice to T.N.
COA rejects a panoply of challenges to TPR and affirms
Kenosha County DC&FS v. K.E.H., 2024AP1101, 2/26/25, District II (1-judge decision, ineligible for publication); case activity
In a dense and fact-dependent appeal stemming from a TPR jury trial, COA applies strict legal standards in order to reject the appellant’s multiple claims of ineffectiveness.
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.
Circuit court properly granted summary judgment based on failure to respond to requests for admission and trial counsel was not ineffective for failing to respond
Kenosha County DC&FS v. A.G.O., 2023AP1305, 1307 & 1308, 5/8/24, District II (one-judge decision; ineligible for publication); case activity
In yet another TPR case involving allegations of ineffective assistance, COA affirms based on hard-to-overcome legal standards.
COA rejects multi-pronged attack on TPR orders
Jackson County Department of Human Services v. I.J.R.,, 2023AP1495-6 4/11/24, District IV (one-judge decision; ineligible for publication); case activity
In yet another beefy TPR appeal presenting multiple issues, COA rejects all of I.J.R.’s arguments and affirms.
COA rejects ineffectiveness claim and challenge to denial of request for new counsel in TPR appeal
Columbia County DH&HS v. S.A.J., 2023AP1884, 2/15/24, District IV (one-judge decision; ineligible for publication); case activity
In a lengthy opinion notable for its treatise-like treatment of the issues, COA rejects S.A.J.’s challenges to her TPR order.
Kenosha County DCFS v. M.T.W.
Kenosha County DCFS v. M.T.W. 2023AP610, 11/15/23, District 2 (one-judge decision; ineligible for publication); case activity
“Mary” appeals from the termination of her parental rights to her daughter “Carrie.” the court of appeals rejects several claims that Mary’s counsel was ineffective and affirms.