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Juveniles – TPR – unfitness
By: WISCONSIN LAW JOURNAL STAFF//December 23, 2014//
Listen to this articleWisconsin Court of Appeals
Civil
Juveniles – TPR – unfitness
APPEAL from an order of the circuit court for Winnebago County: SCOTT C. WOLDT, Judge. Reversed.
Henry S.A. appeals from an order terminating his parental rights to Alandria A.O. The circuit court granted summary judgment on the question of Henry’s
unfitness as a parent because Henry was denied physical placement for more than one year. See Wis. Stat. § 48.415. The underlying order denying physical
placement was based upon Henry’s incarceration. We reverse because the record does not show that the circuit court made the individualized determination
of unfitness that the state and federal constitutions require before termination.
2014AP002404 Winnebago County DHS v. Ashley A. O.
DISTRICT II, Winnebago County, SCOTT C. WOLDT, BROWN, C.J.
Attorneys: For Appellant: Bowe, Ann T. For Respondent: Been, David G.
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