By: Derek Hawkins//October 21, 2020//
WI Court of Appeals – District I
Case Name: State of Wisconsin v. D.S. et al.,
Case No.: 2019AP2230; 2019AP2231; 2019AP2232; 2019AP2233
Officials: BRASH, P.J.
Focus: Ineffective Assistance of Counsel
D.S. appeals the orders of the trial court terminating her parental rights for J.I.S., A.T., E.S. and D.G. She argues that she was denied the effective assistance of counsel at a motion hearing held in June 2019, during which she was without representation. She contends that this was a structural error, which is not subject to a harmless error analysis. D.S. further asserts that her trial counsel was ineffective in his failure to request an adjournment of the dispositional hearing when he had received a substantial amount of discovery the day before the hearing. We disagree and affirm.