On Point blog, page 1 of 13
COA affirms TPR order and denial of postdisposition motion
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.
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.
Defense win: COA reverses TPR dispositional order
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.
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.
COA finds evidence supports TPR dispositional order 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.
COA rejects challenges to TPR dispositional order
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.
COA rejects challenges to TPR dispositional order and affirms
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.
COA rejects challenge to TPR dispositional order and affirms
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.
COA rejects challenge to circuit court’s exercise of discretion on disposition determination
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.
COA affirms summary judgment on grounds to terminate parental rights and upholds discretionary decision that terminating rights in the best interests of children.
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.