On Point blog, page 10 of 10
TPR-elements, grounds of continuing need or protection and services
Walworth Co. DHHS v. Andrea L.O., 2008 WI 46, on Certification
Issue/Holding:
¶6 There are four elements to this ground for termination. First, the child must have been placed out of the home for a cumulative total of more than six months pursuant to court orders containing the termination of parental rights notice. Second, the County Department of Social Services must have made a reasonable effort to provide services ordered by the court.