Joni B. v. State
In Joni B. v. State, 202 Wis. 2d 1, 549 N.W.2d 411 (1996), the supreme court set forth several factors which are to be considered by trial courts in the exercise of their discretionary authority to make such appointments; and the court suggested that the same considerations would apply to decisions to terminate appointments so made.
Among other things, the Joni B. court stated that "when the circuit court either grants or denies a request for counsel, it should memorialize its findings and rationale on the record to facilitate appellate review." Id. at 18.