In re E.A.

Summary

The Vermont Supreme Court held that the Vermont Adoption Act’s twenty-one-day revocation provision does not apply to parental-rights terminations entered in a juvenile CHINS proceeding. Because the parents voluntarily and knowingly agreed to terminate their parental rights under the juvenile statutes, and those statutes provide no parallel revocation right, the court affirmed the termination orders.

Holdings

1. The Vermont Adoption Act does not apply to parental-rights termination proceedings arising under the protective juvenile statutes in chapter 55 of Title 33.
2. The parents had no statutory basis to revoke the termination orders because the Vermont Adoption Act did not apply and the juvenile statutes contain no parallel revocation provision.

Questions Presented

1. Whether the Vermont Adoption Act's twenty-one-day revocation provision applies to parental-rights termination agreements entered in a juvenile CHINS proceeding.
2. Whether the parents' pro se petitions constituted revocations of voluntary relinquishments under the Vermont Adoption Act.
3. Whether the Vermont Adoption Act's revocation period should be tolled because the parents allegedly were advised that their relinquishments were irrevocable.

Disposition

affirmed