Termination of Parental Rights-Harmless Error

By: WISCONSIN LAW JOURNAL STAFF//June 20, 2023//

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WI Court of Appeals – District III

Case Name: Barron County Department of Health and Human Services v. Q. B.

Case No.: 2023AP000037

Officials: Stark, P.J.

Focus: Termination of Parental Rights-Harmless Error

Quan appeals an order terminating his parental rights (TPR) to Nate. Quan argues that the circuit court erroneously exercised its discretion by denying his request for a cautionary instruction after admitting other-acts evidence during the grounds phase of his TPR jury trial. Quan contends that the admission of the other-acts evidence without a cautionary instruction warrants a new trial.

The appeals court assumes without deciding that the circuit court erroneously exercised its discretion by failing to give Quan’s requested cautionary instruction, but the appeals court concludes that the error was harmless.

Affirmed.

Decided 06/13/23

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