WI · jury_instructions
Wis JI-Children 325
Continuing Need of Protection or Services: Three or More CHIPS Orders
The petition in this case alleges that (child) is in continuing need of protection or
services which is a ground for termination of parental rights. Your role as jurors will be to
answer the following questions in the special verdict.
1. Has (child) on three or more occasions been adjudged to be in need of protection
or services and placed outside (his) (her) home pursuant to court orders containing the
termination of parental rights notice required by law?
2. Were the conditions that led to (child)'s placement in each of these occasions
outside (his) (her) home caused by (parent)?
Before (child) may be found to be in continuing need of protection or services,
(petitioner) must prove the following elements by evidence that is clear, satisfactory, and
convincing, to a reasonable certainty.
First, that (child) on three or more occasions was adjudged in need of protection or
services 1 and placed outside (his) (her) home pursuant to court orders containing the
termination of parental rights notice required by law. [Add the following language if there
is no dispute as to this element: Because there is no dispute in the evidence to this question,
I have answered this question. My answer has no bearing whatsoever on what your answer
should be to the other questions in the special verdict form.]
Second, that the conditions that led to (child)'s placement outside (his) (her) home
under each of these orders were caused by (parent). 2 This question asks whether there was a
causal connection between the parent's acts or the parent's failure to act and the conditions
that led to each of the orders placing (child) outside (his) (her) home. The question does not
require you to find that the parent was "the cause" but rather "a cause." The reason for this is
that there may be more than one cause producing the conditions. Before you answer this
question "yes," you must find that the parent's acts or failure to act was a substantial factor in
producing the conditions.
Before you may answer a question in the special verdict "yes," you must be convinced
by evidence that is clear, satisfactory, and convincing, to a reasonable certainty, that the
question should be answered "yes." If you are not so convinced, you must answer the
question "no."
SPECIAL VERDICT
1. Has (child) on three or more occasions been adjudged to be in need of protection
or services and placed outside (his) (her) home pursuant to court orders containing the
termination of parental rights notice required by law?
Answer: (Answered by the Court)
Yes or No
2. Were the conditions that led to (child)'s placement in each of these occasions
outside (his) (her) home caused by (parent)?
Answer:__________________
Yes or No
History
Wis JI-Children 325 (2011). ©2011, Regents, Univ. of Wis. Prepared by the Wisconsin Jury Instructions Committees of the Wisconsin Judicial Conference with the University of Wisconsin Law School; posted by the Wisconsin State Law Library with the University's permission.
Provenance
- Source
- wilawlibrary.gov
- Retrieved
- 2026-09-24
- Edition
- 2026-09-24
- Content hash
89e123c77d80b0a600e38590c4ec46a83d20b4c74b3b058f98daf8eaa324ad76
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