Termination of Parental Rights-Reasonable Efforts

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WI Court of Appeals – District I

Case Name: State of Wisconsin v. M. G.

Case No.: 2025AP002888

Officials: Colón, P.J.

Focus: Termination of Parental Rights-Reasonable Efforts

M. G. M. G. M. G. M. G. The Wisconsin Court of Appeals affirmed orders terminating M. G.’s parental rights to her six children. The court held that the State proved by clear and convincing evidence that the Department of Milwaukee Child Protective Services (DMCPS) made reasonable efforts to provide court-ordered services and that M. G. failed to assume parental responsibility for her three youngest children.

The case began after authorities found unsafe and unsanitary living conditions in the home, including excessive clutter, animal waste, choking hazards, and concerns that older children were caring for younger siblings. One child, Nick, had been diagnosed with failure to thrive. Although M. G. completed a psychological evaluation and participated in some therapy and medical appointments, the court found that DMCPS repeatedly attempted to help her obtain therapy and medication management services, but M. G. was often resistant, inconsistent, and uncooperative. She frequently ignored or blocked communication from her case manager and failed to consistently engage in services.

The court rejected M. G. ’s argument that DMCPS should have done more, concluding that the agency’s obligation was to make “reasonable efforts,” not extraordinary ones, especially when M. G.  herself hindered progress.

The court also upheld the finding that M. G. failed to assume parental responsibility for the three youngest children. Evidence showed the children lived in hazardous conditions, suffered neglect, were exposed to sexual abuse risks involving the paternal grandfather, and had unmet medical and emotional needs. Despite some involvement in visits and appointments, the court concluded M. G. had not exercised substantial responsibility for their care and wellbeing.

Affirmed.

Decided 05/15/26

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