Brown County Department of Human Services v. Terrance M.

¶ 1. Terrance M. appeals two separate pretrial orders denying him a judicial substitution and concluding preclusion doctrines never apply in termination of parental rights proceedings. We conclude preclusion doctrines may be applicable, and we further conclude Wis. Stat. § 48.29 permits judicial substitution in this case. We therefore reverse and remand the orders with directions. Terrance is entitled to judicial substitution and the new judge should determine whether claim or issue preclusion applies to this case.

Background.

¶ 2. On December 26, 2002, the County filed a TPR petition against…