Supreme Court of Vermont

In Re C.P., Juvenile

December 7, 2012193 Vt. 29

Summary

The Court affirmed termination of both parents’ rights and upheld Vermont’s authority to adjudicate the termination proceeding. It held that the unappealed CHINS judgment could not be collaterally attacked as void, and that Vermont had become the child’s home state by the time termination was sought. The Court also held that the evidence supported termination as in the child’s best interests and that the trial court could revisit its nonfinal reasonable-efforts determination. Robinson, J., concurring, would have affirmed on the narrower ground that the parents expressly relinquished their jurisdictional challenge.