Vermont Case Commentaries

Claim Preclusion Does Not Apply in Vermont PCR Proceedings; Repeat Claims Are Governed by Successive-Petition and Abuse-of-the-Writ Doctrines

Date: May 23, 2026

Claim Preclusion Does Not Apply in Vermont PCR Proceedings; Repeat Claims Are Governed by Successive-Petition and Abuse-of-the-Writ Doctrines Introduction In re Joseph Bruyette (2026 VT 18) arises...

Delegation-and-Authority Test for “Statewide” Elections Under Vt. Const. ch. II, § 42 (Noncitizen Voting in Burlington School Elections)

Date: May 16, 2026

Delegation-and-Authority Test for “Statewide” Elections Under Vt. Const. ch. II, § 42 (Noncitizen Voting in Burlington School Elections) Case: Michele Morin and Karen Rowell v. City of Burlington,...

“Temporary” Custody Transfers Without a Time Limit May Be Treated as Final Orders, Shifting the § 668 Burden to the Parent Seeking to Undo Them

Date: May 9, 2026

“Temporary” Custody Transfers Without a Time Limit May Be Treated as Final Orders, Shifting the § 668 Burden to the Parent Seeking to Undo Them Case: Michelle Kendall v. James Kendall (Vt. Supreme...

Conditional Caregiving Does Not Establish “Full and Permanent” Parental Responsibility Under 15C V.S.A. § 501(a)(1)(C)

Date: May 9, 2026

Conditional Caregiving Does Not Establish “Full and Permanent” Parental Responsibility Under 15C V.S.A. § 501(a)(1)(C) Introduction In Mary Zigman v. Sarah Goodwin (Vt. Sup. Ct. May 8, 2026),...

Directory Juvenile Time Limits Require Prejudice for Reversal; CHINS May Rest on Pre-Birth Sibling/Risk Evidence (In re N.B.)

Date: May 9, 2026

Directory Juvenile Time Limits Require Prejudice for Reversal; CHINS May Rest on Pre-Birth Sibling/Risk Evidence (In re N.B.) Vermont Supreme Court (Entry Order), May Term 2026 — In re N.B., Juvenile...

3 V.S.A. § 809b Limits Superior-Court Jurisdiction to Agency Discovery Orders that Compel Action (Not Discovery Denials or Commissioner Interrogatories)

Date: May 9, 2026

3 V.S.A. § 809b Limits Superior-Court Jurisdiction to Agency Discovery Orders that Compel Action (Not Discovery Denials or Commissioner Interrogatories) Case: Otter Creek Solar LLC v. Vermont Public...

Section 5101’s “Preserve the Family” Purpose Does Not Displace the § 5114 Best-Interests Test; “Safety and Timely Permanency” Remains Paramount in TPR

Date: May 9, 2026

Section 5101’s “Preserve the Family” Purpose Does Not Displace the § 5114 Best-Interests Test; “Safety and Timely Permanency” Remains Paramount in TPR 1. Introduction Case: In re H.R. and A.R., Jr.,...

In re C.W. (Vt. May 8, 2026): Unpreserved CHINS-Procedural Objections and Unobjected Hearsay Do Not Defeat Termination; “Unfitness” Is Addressed Through § 5114(a) Best-Interests Findings

Date: May 9, 2026

In re C.W. (Vt. May 8, 2026): Unpreserved CHINS-Procedural Objections and Unobjected Hearsay Do Not Defeat Termination; “Unfitness” Is Addressed Through § 5114(a) Best-Interests Findings Vermont...

Rule 60(b) Is Not a Second Appeal: Clear-and-Convincing Proof Required for Fraud, and Procedural Defaults Bar Relitigation

Date: May 9, 2026

Rule 60(b) Is Not a Second Appeal: Clear-and-Convincing Proof Required for Fraud, and Procedural Defaults Bar Relitigation Introduction Case: James Jerome, Jr. v. Kerry Raheb and Renee Houston (Vt....

Reaffirming Deferential Review and Harmless-Error Principles in Vermont Divorce Property-Division Appeals

Date: May 9, 2026

Reaffirming Deferential Review and Harmless-Error Principles in Vermont Divorce Property-Division Appeals Precedential status. The court issued an Entry Order by a three-justice panel. As the order...

Remand Required When Trial Courts Fail to Make Clear Findings on “Monitoring” or “Surveillance” Under Vermont’s Civil Stalking Statute

Date: May 9, 2026

Remand Required When Trial Courts Fail to Make Clear Findings on “Monitoring” or “Surveillance” Under Vermont’s Civil Stalking Statute Melanie MacEachern v. Kurtis Mellett (Vt. Sup. Ct., May 8, 2026)...

State v. Kent Eaton (2026 VT 14) — “Meaningful” DUI Counsel Consultation Is About Private Opportunity, Not Accurate Advice; Voluntariness Burden Triggered Only by Particularized Coercion Claims

Date: May 5, 2026

State v. Kent Eaton (2026 VT 14): “Meaningful” DUI Counsel Consultation Is About Private Opportunity, Not Accurate Advice; Voluntariness Burden Triggered Only by Particularized Coercion Claims 1....

Preventive Detention Under 13 V.S.A. § 7553a Requires Clear, Particularized Proof That No Release Conditions Can Prevent Violence

Date: May 4, 2026

Preventive Detention Under 13 V.S.A. § 7553a Requires Clear, Particularized Proof That No Release Conditions Can Prevent Violence Introduction In State v. Cameron Waite, the Vermont Supreme Court...

14 V.S.A. § 917 Authorizes Probate Division to Order a Guardian to Reimburse a Ward’s Estate for Fiduciary Misconduct

Date: Apr 27, 2026

14 V.S.A. § 917 Authorizes Probate Division to Order a Guardian to Reimburse a Ward’s Estate for Fiduciary Misconduct I. Introduction In re Miriam Thomas (Paul Thomas, Appellant) (2026 VT 12) is an...

Bail Review Under 13 V.S.A. § 7553: Defendant Must Persuade the Court That Proposed Conditions Reasonably Mitigate Public-Safety Risk

Date: Apr 27, 2026

Bail Review Under 13 V.S.A. § 7553: Defendant Must Persuade the Court That Proposed Conditions Reasonably Mitigate Public-Safety Risk Introduction In State v. Courtney Samplatsky (2026 VT 16), the...

Civil Contempt Requires Clear-and-Convincing Proof of a Present Violation and Bars Collateral Attacks on the Underlying Order

Date: Apr 24, 2026

Civil Contempt Requires Clear-and-Convincing Proof of a Present Violation and Bars Collateral Attacks on the Underlying Order 1. Introduction In Robert Conway v. Bobbi Jo Belden & Kevin Keefe (Vt....

PUC Rule 2.221 Motions Toll the Appeal Period Under V.R.A.P. 4(b)(5)

Date: Apr 21, 2026

PUC Rule 2.221 Motions Toll the Appeal Period Under V.R.A.P. 4(b)(5) 1. Introduction In 2026 VT 13, the Vermont Supreme Court decided a threshold, jurisdictional question arising from two Public...

Parenting a Different Child Is Not Determinative of Best Interests; Stagnation Supports Termination When Noncompliance Is Within the Parent’s Control

Date: Apr 17, 2026

Parenting a Different Child Is Not Determinative of Best Interests; Stagnation Supports Termination When Noncompliance Is Within the Parent’s Control 1. Introduction Case: In re M.D. and M.D.,...

Spousal-Privilege Exceptions and Procedural Discretion in Vermont Relief-from-Abuse Hearings

Date: Apr 16, 2026

Spousal-Privilege Exceptions and Procedural Discretion in Vermont Relief-from-Abuse Hearings 1. Introduction Christine Scott v. Johnathan Scott (Vt. Sup. Ct., Apr. 10, 2026) arises from a...

Reasonable Efforts Are Not a Prerequisite to Termination: Stagnation and Parental Noncontact—Including Consequences of Incarceration—Support TPR

Date: Apr 16, 2026

Reasonable Efforts Are Not a Prerequisite to Termination: Stagnation and Parental Noncontact—Including Consequences of Incarceration—Support TPR Important context: The decision is an Entry Order...