On Point: 1. Best interests of the child

Pierce County Dept of Human Services v. K.D.B., 2025AP2643, 6/30/26, District III (ineligible for publication); case activity

“Kevin” appeals the order terminating his parental rights to his daughter, and an order denying his motion for postdisposition relief. He contends that the evidence was insufficient to support the jury’s verdict and his trial attorney provided ineffective assistance at the grounds trial. He also argues that the circuit court erroneously exercised its discretion by concluding that the termination of his parental rights was in his daughter’s best interests. COA affirms.

State v. R.R.L., 2026AP956, 7/1/26, District II (ineligible for publication); case activity

“Roger” contends that the circuit court erroneously exercised its discretion at disposition because, in determining that termination was in the best interest of his son, “Marcus,” the court failed to consider relevant facts regarding Marcus’s relationships with other family members even though such relationships may not have been substantial. COA affirms.

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.

State v. J.G., III, 2025AP469-474, 5/15/26, District I (ineligible for publication); case activity

Although J.G. levies a number of appellate attacks, COA finds his arguments uniformly unavailing and affirms.

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.

Portage County v. Z.D.R., 2025AP1330 & 20205AP1331, 10/2/25, District IV (ineligible for publication); case activity

The COA affirmed the circuit court’s orders terminating Z.D.R.’s parental rights to his two children, finding that summary judgment was appropriate regarding grounds to terminate because there was no factual dispute that he abandoned the children, and that the circuit court did not erroneously exercise its discretion when it found that terminating Z.D.R.’s parental rights was in the best interests of the children.

Sheboygan County DH&HS v. A.W., Sr., 2024AP907, District II, 10/30/24 (one-judge decision; ineligible for publication); case activity

The COA rejects A.W., Sr.’s claims that the circuit court failed to take testimony to support the finding of unfitness when he pled no contest to grounds, and that the court’s decision to terminate his parental rights at disposition was an erroneous exercise of discretion.

State v. S.O., 2024AP1350, 10/8/24, District I (one-judge decision; ineligible for publication); case activity

S.O. (“Sarah”) challenges the order terminating her parental rights to her son, “Daniel,” arguing that the circuit court erroneously exercised its discretion at disposition when it failed to explicitly consider Daniel’s wishes.

State v. H.C., 2023AP1950, 3/5/24, District I (one-judge decision; ineligible for publication); petition for review granted 9/11/24; reversed 6/3/25 case activity

In an interesting decision that seems almost guaranteed to invite review by SCOW, COA departs from the plain language of the statute and reads a burden of proof requirement into the TPR dispositional procedure.

Sheboygan County DHHS v. J.L., 2023AP1884, 1/3/24, District 2 (one-judge decision; ineligible for publication); case activity

In yet another appeal of the circuit court’s discretionary decision to terminate a parent’s rights, COA easily rejects J.L.’s invitation to reweigh the evidence.