Termination of Parental Rights

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WI Court of Appeals – District IV

Case Name: Jefferson County Department of Human Services v. J.V.

Case No.: 2015AP2622; 2015AP2623; 2015AP2624

Officials: KLOPPENBURG, P.J

Focus: Termination of Parental Rights

This case concerns the termination of parental rights of J. V. with respect to three of her minor children, M. K. C., N. N. C., and A. G. C. 2 The circuit court found as grounds for termination that the children were in continuing need of protection or services under WIS. STAT. § 48.415(2). The mother argues that the circuit court erred in excluding relevant evidence of events that occurred after the date the termination of parental rights petitions were filed, specifically relating to an order for return of the mother’s eldest child, M. V., who was not subject to the TPR proceedings. As I explain below, assuming without deciding that the postpetition evidence relating to M. V. was relevant to the children’s TPR proceedings, any error in excluding that evidence was harmless. Therefore, I affirm

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