On Point blog, page 1 of 5

COA rejects challenge to exercise of discretion at TPR disposition hearing

State v. Y.M., 2026AP1212, 8/27/26, District I (ineligible for publication); case activity

“Yolanda” challenges the circuit court’s exercise of discretion at disposition, arguing that the evidence lacked “complete and meaningful testimony” from the children’s foster placements and potential adoptive parents. COA rejects these arguments and affirms.

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COA rejects ineffectiveness arguments in TPR and 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.

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COA addresses multi-pronged attack on TPR orders and affirms

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.

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Defense win: COA upholds jury’s verdict in favor of TPR respondent

J.R.P. v. W.P.M., 2024AP1535, 2/19/26, District IV (ineligible for publication); case activity

In a rare sufficiency challenge pursued by the petitioner, COA applies a deferential standard of review and affirms.

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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.

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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.

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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.

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Mother’s sufficiency of the evidence challenge rejected because circuit court entered a TPR dispo order “a reasonable judge could reach”

State v. E.S., 2024AP395 & 396, 5/21/24, District I (one-judge decision; ineligible for publication); case activity

E.S. (“Emily”) challenges the sufficiency of the evidence supporting the circuit court’s finding that her children did not have a substantial relationship with her and that they were too young to express their wishes. The court of appeals affirms after reviewing the record and concluding that the circuit court properly exercised its discretion by considering the statutorily required disposition factors and reaching a decision that a reasonable judge could reach Op., ¶26.

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COA rejects sufficiency and erroneous exercise of discretion challenges in TPR appeal

State v. M.E.E., 2023AP1510, 11/28/23, District I (one-judge decision; ineligible for publication); case activity

In a dense and fact-dependent opinion, COA affirms under well-settled standards of review.

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Circuit court properly exercised discretion when it entered an individualized order terminating parental rights of one parent

State of Wisconsin v. J.L.A., 2023AP424, District I, 6/27/23, 1-judge decision ineligible for publication; case activity (briefs not available)

In a TPR appeal with a typically tragic fact pattern, the court of appeals defers to the circuit court’s decision to terminate “Julia’s” parental rights.

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