Winnebago County DSS v. Darrell A

In Winnebago County DSS v. Darrell A., 194 Wis. 2d 627, 534 N.W.2d 907 (Ct. App. 1995) the law amended the grounds for termination to include the intentional homicide of the child's parent several years after Darrell A. had been convicted of murdering Amanda's mother. In concluding that the application of the amended statute to Darrell A. was proper, the court held "that sec 48.415(8), Stats., does not constitute an ex post facto law." Id. at 633-34. This was so, the court declared, because the passage of an amendment to 48.415 was not done with a punitive intent, and thus, the statute could not be an ex post facto violation. See id. at 638.