Rock County Human Services Department v. S. P.

CourtCourt of Appeals of Wisconsin
DecidedJuly 16, 2026
Docket2025AP000445
StatusUnpublished

This text of Rock County Human Services Department v. S. P. (Rock County Human Services Department v. S. P.) is published on Counsel Stack Legal Research, covering Court of Appeals of Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rock County Human Services Department v. S. P., (Wis. Ct. App. 2026).

Opinion

COURT OF APPEALS DECISION NOTICE DATED AND FILED This opinion is subject to further editing. If published, the official version will appear in the bound volume of the Official Reports. July 16, 2026 A party may file with the Supreme Court a Samuel A. Christensen petition to review an adverse decision by the Clerk of Court of Appeals Court of Appeals. See WIS. STAT. § 808.10 and RULE 809.62.

Appeal No. 2025AP445 Cir. Ct. No. 2024JC20

STATE OF WISCONSIN IN COURT OF APPEALS DISTRICT IV

IN THE INTEREST OF L.D.H., A PERSON UNDER THE AGE OF 18:

ROCK COUNTY HUMAN SERVICES DEPARTMENT,

PETITIONER-CO-APPELLANT,

V.

S. P. AND GUARDIAN AD LITEM, JENNIFER L. NASH ELLIOTT,

RESPONDENTS,

R. M. S.,

RESPONDENT-APPELLANT.

APPEAL from an order of the circuit court for Rock County: MICHAEL A. HAAKENSON, Judge. Affirmed.

Before Blanchard, Nashold, and Taylor, JJ. No. 2025AP445

Per curiam opinions may not be cited in any court of this state as precedent

or authority, except for the limited purposes specified in WIS. STAT. RULE 809.23(3).

¶1 PER CURIAM. The Rock County Human Services Department (the County) and R.M.S. appeal a circuit court order that dismissed R.M.S. as a party from this CHIPS case.1 The court dismissed R.M.S. on the ground that, even though he has been married to the mother of the child at all pertinent times, he is not a “parent” of the child under the definition of “parent” that applies in CHIPS cases. See WIS. STAT. § 48.02(13) (defining “parent” for purposes of chapter 48 proceedings). In briefing adopted by R.M.S., the County argues that R.M.S. is a “parent” of the child under § 48.02(13), primarily because that provision must be construed in light of the presumption of paternity in WIS. STAT. § 891.41, under which R.M.S. is defined to be “the natural father” of the child.

¶2 We conclude that discussion of WIS. STAT. § 48.02(13) by our supreme court in State v. James P., 2005 WI 80, 281 Wis. 2d 685, 698 N.W.2d 95, supports the circuit court’s interpretation and application of WIS. STAT. § 48.02(13) to the facts here. This is because our supreme court has rejected the only potential interpretation of § 48.02(13) under which R.M.S. could be deemed a “parent” for purposes of CHIPS proceedings. Accordingly, we affirm.

BACKGROUND

¶3 This CHIPS case involves one child, L.D.H., who was born in January 2024. It is undisputed that at all pertinent times—when the child was conceived, at

1 CHIPS is the common acronym used for “child in need of protection or services,” as addressed in the Wisconsin Children’s Code, WIS. STAT. ch. 48 (2023-24). Marinette County v. Tammy C., 219 Wis. 2d 206, 208 n.1, 579 N.W.2d 635 (1998). All references to the Wisconsin Statutes are to the 2023-24 version unless otherwise noted.

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the time of birth, and throughout the CHIPS proceedings—the mother, S.P., and R.M.S. were married.

¶4 In June 2024, the County filed the CHIPS petition that initiated this case, seeking court intervention on behalf of the child. The petition alleged that the child was in need of protection and services based on the grounds identified in WIS. STAT. § 48.13(10) and (10m), provisions that we quote and refer to in the course of our discussion below. The petition identified the mother as one parent, but it did not identify R.M.S. as the other parent. Instead, it identified B.H. as the child’s “alleged father,” based on the mother’s statements to a social worker about who the biological father might be.

¶5 The petition alleged that the mother’s alcohol use rendered her “unable to make safe decisions for the Child or prior[i]tize the Child’s basic needs.” The petition also alleged that B.H. was absent from the child’s life and that, in any case, he was not able to provide for the basic needs of the child. The County took temporary physical custody of the child.

¶6 After the petition was filed, R.M.S. was identified as having been married to the mother at all pertinent times, including when the child was born. R.M.S. was served with a notice of the CHIPS case in July 2024, and an attorney was appointed to represent him in the case.

¶7 Genetic testing was ordered, and B.H. and R.M.S. were both excluded as the child’s biological father.2 No party has questioned the authenticity or accuracy of either genetic test for purposes of this appeal.

2 B.H. is not a party to this appeal, and no one argues that his rights were violated in this CHIPS proceeding.

3 No. 2025AP445

¶8 During a permanency plan hearing in December 2024, a social worker for the County gave unrebutted testimony that the social worker had asked the mother to identify anyone who might be the father, other than B.H. or R.M.S., and that the mother had not identified anyone else.

¶9 After the parties received the result of the genetic test excluding R.M.S. as the biological father, the circuit court made an initial observation at a hearing in December 2024 that it would likely be appropriate for the court to dismiss R.M.S. from the case. But, after hearing objections, the court requested briefing on the issue.

¶10 The guardian ad litem (GAL) for the child argued that R.M.S. should be dismissed from the CHIPS proceeding because he is not “a parent,” based on the definition of “parent” in WIS. STAT. § 48.02(13).3 The GAL also alleged that the mother and R.M.S. “are not in a relationship” and “don’t reside together,” and that R.M.S. “has only recently had minimal contact with this child.” The GAL had no objection to R.M.S. acting as an informal “family support, as other family members might be; but beyond that, I think we need to look to establish paternity for the child, and that we need to proceed in that fashion.”

3 WISCONSIN STAT. § 48.02(13) states in pertinent part:

“Parent” means a biological parent, a husband who has consented to the artificial insemination of his wife under [WIS. STAT.] 891.40, or a parent by adoption. If the child is a nonmarital child who is not adopted or whose parents do not subsequently intermarry under [WIS. STAT. §] 767.803, “parent” includes a person conclusively determined from genetic test results to be the father under [WIS. STAT. §] 767.804 or a person acknowledged under [WIS. STAT. §] 767.805 or a substantially similar law of another state or adjudicated to be the biological father.

4 No. 2025AP445

¶11 In contrast, in written briefing and oral argument, the County contended that R.M.S. should remain in the case as a “parent” of the child for purposes of the CHIPS proceeding under the definition of “parent” in WIS. STAT. § 48.02(13). The County contended that this is because § 48.02(13) must be construed in light of the presumption of paternity raised by R.M.S.’s marriage to the mother under WIS. STAT. § 891.41.4 The County also noted that no other man had been identified as the father and that B.H. had been excluded as the biological father by genetic testing. Attorneys for both R.M.S. and the mother agreed that R.M.S. should not be dismissed from the case, citing the same reasons.

¶12 At a hearing in January 2025, the circuit court recognized that R.M.S. is presumed to be the “natural father” of the child under WIS. STAT. § 891.41. But

4 WISCONSIN STAT. § 891.41 states in its entirety:

(1) A man is presumed to be the natural father of a child if any of the following applies:

(a) He and the child’s natural mother are or have been married to each other and the child is conceived or born after marriage and before the granting of a decree of legal separation, annulment or divorce between the parties.

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Bluebook (online)
Rock County Human Services Department v. S. P., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rock-county-human-services-department-v-s-p-wisctapp-2026.