On Point: G. Disposition, Secs. 48.426-427

State v. E.L., 2026AP1497, 9/9/26, District I (ineligible for publication); case activity

“Emily” appeals the circuit court’s order terminating her parental rights to her child, “Gretchen,” arguing that the court erroneously exercise of discretion when it found that termination was in Gretchen’s best interests. Emily claims the court failed to consider whether Gretchen had substantial relationships with other family members, and whether it would be harmful to her if those relationships were severed. COA affirms.

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.

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.

Waupaca County Department of Health & Human Services v. C.J.T., 2026AP794, 6/11/26, District IV (ineligible for publication); case activity

CJT appeals the circuit court order terminating his parental rights to his son, JJT, arguing that the court failed to demonstrate that it considered all of the required factors at disposition. Despite the deferential standard of review to a TPR dispositional order, COA agrees, reversing the termination order and remanding for a proper exercise of discretion.

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 Department of Human Services v. B.L.J., 2026AP400-402, 5/7/26, District IV (ineligible for publication); case activity

In yet another decision applying the deferential standard of review to a TPR dispositional order, COA rejects the appellant’s arguments which ignore that standard of review.

Brown County Health &Human Services v. J.L., 2026AP176, 5/1/26, District III (ineligible for publication); case activity

“Julie” challenges the circuit court’s exercise of discretion at disposition as to two factors of consideration. However, the deferential standard of review applicable to dispositional decisions results in affirmance.

Jefferson County DHS v. G.J.J., 2025AP2491, 3/5/26, District IV (ineligible for publication); case activity

While G.J.J. gets closer than most–and his arguments even give COA “pause”–ultimately, the deferential standard of review applicable to dispositional decisions results in affirmance.

State v. L.Z., 2025AP2731-32, 2/17/26, District I (ineligible for publication); case activity

Although L.Z. tries to capitalize on certain statements in the court’s oral ruling as giving a foothold for her appellate challenge, the standard of review means the argument attacking a discretionary decision goes nowhere.

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.