On Point blog, page 1 of 1
COA affirms TPR order in appeal challenging sufficiency of the state’s “reasonable efforts” and ADA compliance
State v. G.L., 2026AP865, 7/1/26, District I (ineligible for publication); case activity
“Gwen” challenges the termination of her rights to her child, “Annie,” on the basis that the state presented insufficient evidence to the jury that the Division of Milwaukee Child Welfare (DMCW) made a reasonable effort to provide her with court-ordered services and that DMCW did not comply with the Americans with Disabilities Act (ADA). COA affirms.
TPR court properly considered evidence of prior TPRs
State v. S.T., 2021AP1278-1280, 10/26/21, District 1 (1-judge opinion, ineligible for publication); case activity
The circuit court terminated S.T.’s parental rights to three of her children after she brought one of them (a 5-month old twin) to the hospital with severe burns on his body. S.T. appealed arguing that during the grounds phase of the TPR trial the circuit court erroneously relied on irrelevant evidence–testimony regarding past CHIPS and TPR proceedings that predated the births of these three children.
TPR – grounds; continuing CHIPS, failure to assume parental responsibility instead of continuing parental disability
State v. Angie A., 2012AP2240, District 1, 2/20/13; court of appeals decision (1-judge, ineligible for publication); case activity
The state properly brought TPR petition alleging grounds under Wis. Stat. § 48.415(2) (continuing need of protection and services) and § 48.416(6) (failure to assume parental responsibility) instead of § 48.415(3) (continuing parental disability, a ground that specifically targets parents with a mental illness or developmental disability), because the state could and did make a reasonable effort to provide Angie A.