In re A.D., Juvenile

Summary

The Vermont Supreme Court affirmed the termination of the mother's parental rights to A.D., concluding that she had stagnated in her progress toward reunification and would not be able to resume parental duties within a reasonable time. The court held that findings concerning visitation, housing, substance-abuse treatment, domestic-violence services, and involvement in the child's medical and educational care supported termination.

Holdings

1. The trial court properly found a sufficient change in circumstances because Mother's ability to care properly for A.D. had stagnated and she had failed to make adequate progress in addressing the conditions that led to state custody.
2. The trial court properly concluded that Mother would not be able to resume parental duties within a reasonable time and that termination was in A.D.'s best interests.
3. Any alleged error did not warrant reversal because other substantial evidence independently supported the findings of stagnation and Mother's inability to resume parenting within a reasonable time.

Questions Presented

1. Whether the trial court properly found a change in circumstances based on Mother's stagnation in progress toward reunification.
2. Whether the trial court properly concluded that Mother could not resume parental duties within a reasonable time.
3. Whether any error in relying on Mother's inability to obtain housing or failure to attend school and medical appointments warranted reversal.

Disposition

affirmed