On Point: 40. TPRs

State v. A.L., 2025AP177, 4/22/25, District I (1-judge decision, ineligible for publication); case activity

Despite the respondent’s claim that she was never given notice of the time for a jury status hearing, COA affirms the circuit court’s default finding.

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.

J.H. v. J.L.B., 2025AP85, 4/3/25, District IV (1-judge decision, ineligible for publication); case activity

COA reviews the grant of summary judgment on abandonment and failure to assume parental rights de novo and concludes that there are issues of material fact as to each ground. The court therefore reverses and remands for a fact-finding hearing.

Brown County v. N.H., 2024AP1991-1993, 4/2/25, District III (1-judge decision, ineligible for publication); case activity

Although the County erred by listing the wrong date in a published notice, COA affirms given the court’s factual findings that the respondent was served by mail.

Kenosha County DC&FS v. K.E.H., 2024AP1101, 2/26/25, District II (1-judge decision, ineligible for publication); case activity

In a dense and fact-dependent appeal stemming from a TPR jury trial, COA applies strict legal standards in order to reject the appellant’s multiple claims of ineffectiveness.

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.

M.S. v. R.F., 2024AP814, District I, 11/19/24 (one-judge decision; ineligible for publication); case activity

The Court of Appeals affirmed the circuit court’s order granting M.S. (referred to as Michelle) relief from her voluntary termination of parental rights because her decision to terminate was premised on terminating R.F.’s (referred to as Richard) parental rights, and the Court of Appeals in a previous decision remanded the case to the circuit court for a new trial on whether grounds existed to terminate Richard’s rights.

N.C. v. R.G., 2024AP996, District II, 11/20/24 (one-judge decision; ineligible for publication); case activity

In a TPR appeal with a very unusual posture, COA rejects the petitioner’s appeal given her failure to abide by the rules of appellate procedure.

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. 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.