In re T.R.M
In In re T.R.M., 100 Wis. 2d 681, 688, 303 N.W.2d 581 (1981) an involuntary termination proceeding, the supreme court reversed a termination order for two reasons.
First, no specific findings of fact were made with respect to the factual grounds supporting the order. See In re T.R.M., 100 Wis. 2d at 686.
Second, there was no specific finding that it would be in the child's best interests to terminate the father's parental rights.
"The trial court findings are also deficient with respect to a lack of a specific and formal determination regarding the best interests of T. R. M. Where this is an issue in a court proceeding, the trial court is under an obligation to make findings with regard to the best interests of the child in relation to the evidence adduced. The failure to make this formal finding in and of itself is cause for remand of the matter for completion of the record." (In re T.R.M., 100 Wis. 2d at 687.)