On Point: E. Procedure

State v. S.B.T., 2026AP1890, 11/4/26, District II (ineligible for publication); case activity

Although S.B.T. presents a number of mitigating facts to excuse her nonappearance, COA holds the circuit court did not erroneously exercise its discretion and rejects her challenges to the disposition.

State v. M.R., 2026AP1742 & 2026AP1743, 10/20/26, District I (ineligible for publication); case activity

COA holds that the circuit court properly exercised its discretion when it found “Margo” in default when she missed one court appearance and affirms orders terminating her parental rights.

Barron County v. K.L.P., 2026AP460 & 2026AP461, 7/21/26, District III (ineligible for publication); case activity

The COA held that the circuit court did not lose competency to enter disposition orders in an action to terminate parental rights if it accepts a no-contest plea to the grounds for termination without hearing testimony, even if Wis. Stat. § 48.422(3) requires testimony.

Waupaca County Department of Health & Human Services v. J.L.C. and M.M.C., 2026AP498 and 647, 6/25/26, District IV (ineligible for publication); case activity

JLC and MMC each appeal the circuit court order terminating their parental rights to their child, CMC, arguing that the court erred in granting Waupaca County’s motion for summary judgment on grounds. COA concludes that the ground on which SJ was granted, continuing denial of visitation, requires the county to prove that the parents received adequate notice of the conditions of resuming visitation, and the county cannot make this showing under the facts. Therefore, COA reverses the order and remands with directions that the circuit court grant partial summary judgment to both parents on the continuing denial of visitation ground. 

Green County v. K.M.S., 2025AP199, 6/18/26, District IV (ineligible for publication); case activity

Applying an exceptionally deferential review to K.M.S.’s ineffectiveness claims, COA affirms in the face of a somewhat confusing appellate record.

Sawyer County Health & Human Services v. D.K., 2025AP2832, 3/12/26, District III (ineligible for publication); case activity

The COA reversed the order terminating “Daniel’s” parental rights after summary judgment was granted at the grounds phase because genuine issues of material fact exist whether the County made reasonable efforts to provide services.

Chippewa County v. C.F., 2025AP1744, 1/21/26, District III (ineligible for publication); case activity

C.F. appeals the order terminating her parental rights to her son, arguing the circuit court erred by granting the county’s motion for partial summary judgment as to grounds. COA agrees that the order denying her visitation did not give adequate notice of the conditions she needed to meet in order to be granted visitation.

Marquette County DHS v. J.J., 2025AP1963, 1964 & 1965, 12/18/25, District IV (ineligible for publication); case activity

J.J. stipulated to the existence of grounds for termination but contested disposition. He now appeals the orders terminating his parental rights to three of his children, arguing that the circuit court erred because it based its termination decision in part on his poverty. COA concludes that the court did not erroneously exercise its discretion and affirms.

Sheboygan County DH&HS v. Z.N., 2025AP1817, 11/7/25, District II (ineligible for publication); case activity

In an unpublished but citable case, COA clarifies there is no requirement that respondent appear in person for a voluntary termination of parental rights in an ICWA case and reverses the circuit court’s default finding.

Kenosha County v. V.L.W., 2025AP1914, 11/12/25, District II (ineligible for publication); case activity

COA rejects “Victor’s” arguments on appeal, which are all based on the continuing CHIPS “substantial likelihood” provision applying in his case. COA concludes that Victor did not prove this provision, which requires that the has been placed outside the home for less than 15 of the most recent 22 months, should apply.