On Point blog, page 1 of 8
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 affirms verdict finding grounds to terminate parental rights for failing to assume parental responsibilities.
Taylor County Human Services v. A.B., 2025AP633, 2025AP634, 2025AP635, 2025AP636, 7/29/25, District II (ineligible for publication); case activity
The COA affirms the circuit court’s orders terminating “Adam’s” parental rights, while emphasizing the heavy burden placed on the party seeking to overturn a jury’s verdict.
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 reverses grant of summary judgment in TPR, holds that issues of material fact exist as to abandonment and failure to assume
J.H. v. J.L.B., 2025AP85, 4/3/25, District IV (1-judge decision, ineligible for publication); case activity
COA reviews the grant of summary judgment on abandonment and failure to assume parental rights de novo and concludes that there are issues of material fact as to each ground. The court therefore reverses and remands for a fact-finding hearing.
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.
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.
COA: Evidence sufficient to affirm verdict finding grounds to terminate parental rights; cir. ct. did not erroneously exercise discretion in terminating rights.
Waukesha County Dept. of Health & Human Services v. M.M.M., 2024AP1622, 10/30/24, District II (one-judge decision; ineligible for publication); case activity
In a straightforward case addressing sufficiency of the evidence, the COA affirmed the circuit court’s order to terminate M.M.M’s (referred to as Mary) parental rights. The Court found that the evidence was sufficient to support the jury’s verdict finding grounds to terminate her parental rights, and the circuit court did not erroneously exercise its discretion when it determined terminating Mary’s parental rights to her son (referred to as Neal) was in his best interest.
COA rejects “love and affection” defense in sad TPR case
State v. S.F., 2023AP1699, 1702-1705, 12/12/23, District I (one-judge decision; ineligible for publication); case activity
In an all-around sad TPR appeal, S.F. (“Sabrina”) challenges (1) the sufficiency of the evidence supporting the court’s finding that grounds existed to terminate and (2) the court’s discretionary decision to terminate her parental rights to her five children. Despite the fact that neither court doubted Sabrina’s love and affection for her children, the court of appeals affirms.