State v. L.C.

CourtCourt of Appeals of Wisconsin
DecidedJuly 28, 2020
Docket2020AP000796
StatusUnpublished

This text of State v. L.C. (State v. L.C.) 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
State v. L.C., (Wis. Ct. App. 2020).

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 28, 2020 A party may file with the Supreme Court a Sheila T. Reiff 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. 2020AP796 Cir. Ct. No. 2018TP213

STATE OF WISCONSIN IN COURT OF APPEALS DISTRICT I

IN RE THE TERMINATION OF PARENTAL RIGHTS TO M.S. JR., A PERSON UNDER THE AGE OF 18:

STATE OF WISCONSIN,

PETITIONER-RESPONDENT,

V.

L.C.,

RESPONDENT-APPELLANT.

APPEAL from an order of the circuit court for Milwaukee County: MARK A. SANDERS, Judge. Affirmed. No. 2020AP796

¶1 WHITE, J.1 L.C. appeals the circuit court’s order terminating her

parental rights to her child, M.S. Jr., on the petition of the Milwaukee County

Department of Human Services. She asks this court to vacate the order and

remand for a new trial. She argues that the trial court erroneously exercised its

discretion when it struck her contest posture as a sanction and entered an order of

default judgment on the grounds of termination of L.C.’s parental rights. We

conclude that the default sanction was not an erroneous exercise of discretion

because a trial court may default a party as a sanction for egregious conduct and

the record supports the trial court’s findings. Accordingly, we affirm.

BACKGROUND

¶2 On September 10, 2018, the State filed a petition to terminate L.C.’s

parental rights to her son, M.S. Jr. The petition alleged that M.S. Jr. remained in

continuing need for protection or services (continuing CHIPS) and that L.C. had

failed to assume parental responsibility.

¶3 M.S. Jr. was born March 31, 2016, and he lived in the care of his

mother, L.C. (and some of the time in care of his father) until the Division of

Milwaukee Child Protective Services (DMCPS) removed him in April 2017. He

was removed from L.C.’s home because he was diagnosed with failure to thrive at

1 This appeal is decided by one judge pursuant to WIS. STAT. § 752.31(2)(e) (2017-18). All references to the Wisconsin Statutes are to the 2017-18 version unless otherwise noted.

2 No. 2020AP796

approximately one year of age, when he weighed less at his one-year medical

examination than at his six-month medical examination. He was placed with a

foster care family in April 2017, where he remained through the pendency of these

proceedings. On October 8, 2018, the Honorable Christopher Foley2 heard the

State’s initial petition seeking involuntary termination of L.C.’s parental rights to

M.S. Jr. The circuit court referenced that L.C. had been hospitalized for mental

health issues, but deferred appointing a guardian ad litem (GAL). The circuit

court told L.C. “you need to appear for all the hearings. You need to be on time

for the hearings. You need to stay in touch with whoever your lawyer turns out to

be.”

¶4 L.C. appeared without counsel at the return hearing date on

November 6, 2018; however, the circuit court sent her to the State Public

Defender’s Office for appointment of counsel. She appeared with counsel at the

third hearing date, December 14, 2018, at which she contested the petition and

reserved her right to a jury trial. The circuit court reminded L.C. that “You need

to appear for all the hearings, be on time, stay in touch with your lawyers.” L.C.

appeared in person at a permanency plan review hearing on February 12, 2019.

2 During the rotation of judicial calendars, this case moved from the Honorable Christopher Foley to the Honorable Mark A. Sanders. For ease of reading, Judge Foley will be referred to as the circuit court and Judge Sanders as the trial court.

3 No. 2020AP796

¶5 After L.C. failed to appear at depositions on February 21, 2019, and

March 7, 2019, the State moved for sanctions under WIS. STAT. § 804.12

requesting that the trial court refuse to allow L.C. to contest claims in the grounds

phase of the TPR proceedings. On March 19, 2019, instead of having the final

pretrial for the scheduled March 25, 2019 jury trial, the circuit court addressed the

State’s motion for sanctions. L.C. appeared with counsel, who explained to the

circuit court that she had been unable to contact L.C. since December 14, 2018,

and she wondered if L.C was homeless. Counsel stated that her letters to L.C.

have been returned and her phone calls went to a non-working number. Further,

L.C.’s counsel stated that she thought a competency examination was needed

based on her concerns about L.C.’s understanding of this process. L.C. informed

the circuit court she would not attend a competency examination. The circuit

court appointed a GAL pursuant to WIS. STAT. § 48.235(1) to short-cut

competency concerns. The circuit court informed L.C. that she must appear for

the deposition because if she did not, there was a strong likelihood she would be

sanctioned by taking away her right to trial on the grounds phase of this case.

¶6 On July 8, 2019, L.C. appeared in person and with counsel at the

final pretrial hearing for the rescheduled jury trial. However, the circuit court was

waylaid to address the State’s renewed motion for sanctions for L.C.’s failure to

appear for scheduled depositions on May 3, 2019, and May 20, 2019. L.C.’s

counsel argued against sanctions because L.C. consistently attended court and

4 No. 2020AP796

made an effort to stay on top of this case and the CHIPS case. The circuit court

described L.C.’s failure to attend depositions as egregious because it was

persistent and impaired the opposing parties’ efforts to prepare for trial. However,

the circuit court also weighed that L.C. has emotional, psychological and

competency issues that were unquestionably impacting her ability to do what she

was required to do. The circuit court considered but did not decide whether L.C.

was attempting to subvert and delay the TPR process. It also pondered if the

opposing parties needed to depose L.C. to proceed on the grounds phase of the

TPR. It considered taking the motion under advisement with the thought that if

the lack of deposition interfered with the State’s ability to make its case, then the

circuit court could default L.C. Nevertheless, the circuit court was troubled that

L.C. had blown up two trial dates, which pointed toward egregious conduct.

¶7 At the next hearing on July 15, 2019, L.C.’s counsel appeared but

informed the circuit court that L.C. was outside the courtroom but was refusing to

enter and stated that she would fire counsel if she was forced to enter. The circuit

court set a fifth deposition date with the stated expectation that if L.C. did not

show up and fully cooperate, then she would not be a trial participant.

¶8 L.C. missed the scheduled deposition on August 1, 2019. The State

filed its third motion for sanctions to strike L.C.’s trial posture for missing five

deposition dates, and a hearing was scheduled for September 20, 2019. However,

on that date, L.C. did not appear and the trial court questioned whether she was

5 No. 2020AP796

sent notice at the proper address. L.C.’s counsel was at a trial in another county

and did not appear. The trial court adjourned the hearing over the objection of

M.S. Jr.’s GAL.

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State v. L.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lc-wisctapp-2020.