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

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.

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.

State v. H.C., 2025 WI 20, 6/3/25, affirming an unpublished court of appeals decision; case activity

In a decision that has been awaited by TPR practitioners, all seven justices affirm COA’s mandate, with five justices joining in a majority opinion which concludes there is no burden of proof applicable at a dispositional hearing.

Waukesha County v. A.T., 2025AP167, 4/2/25, District II (1-judge decision, ineligible for publication); case activity

“Amber” appeals from an order terminating her parental rights to her 6-year-old daughter, “Holly.” She argues the circuit court erroneously exercised its discretion at disposition. COA affirms under the deferential, erroneous exercise of discretion standard.

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.