In re D.M. & T.P.

Summary

The Vermont Supreme Court affirmed the termination of a mother’s parental rights in two children based on parental stagnation and the children’s best interests. The court held that the mother’s inability to consistently apply parenting skills constituted stagnation even though she complied with the service plan and temporarily lost access to therapy because her therapist became ill. The court also concluded that the children’s need for permanency and stability outweighed the harm from ending their relationship with their mother.

Holdings

1. The juvenile court properly found parental stagnation because Mother's inability to improve her parenting and protective behavior persisted despite her participation in the service plan; the temporary interruption of therapy with one therapist did not preclude that finding.
2. Termination was proper because the children's need for a permanent, predictable, and safe home outweighed the emotional harm from ending their relationship with Mother, which the juvenile court found would not be irreparable.

Questions Presented

1. Whether the juvenile court properly found changed circumstances based on parental stagnation when Mother's therapy was interrupted for several months by circumstances beyond her control.
2. Whether termination of Mother's parental rights was improper because of the loving bond between Mother and the children and the potential emotional harm from severing that relationship.

Disposition

affirmed