In re K.F., Juvenile

Summary

The Supreme Court of Vermont affirmed the family court's order terminating father's residual parental rights to K.F., born October 2002. Rejecting father's argument that the Department of Social and Rehabilitation Services engineered the circumstances supporting termination by failing to provide him services and denying visitation, the court held that father bore sole responsibility for his frequent incarceration, his failure to maintain consistent contact with SRS, and his lack of a bond with K.F. The court further held that a material change in circumstances since the initial disposition order was evident from the record despite the family court's failure to make an explicit finding, and that the family court did not abuse its discretion in concluding termination was in K.F.'s best interests.