In Re A.B. & B.B., Juveniles, 336 A.3d 437

In a child welfare case, the family division terminated a father's parental rights to A.B. and B.B. on January 2, 2025.
The State filed a motion on January 9, 2025, to amend the final order to correct a clerical error (child’s birthdate) and clarify residual parental rights.
The court granted these amendments and issued a corrected final order on February 10, 2025.
Father filed his appeal on the same day the corrected order was issued.
The State moved to dismiss the appeal as untimely, arguing corrections under Rule 60(a) do not toll the appeal period, relying on prior Vermont Supreme Court precedent.
The central question was if a Rule 60(a) motion, filed within 28 days of the original order, tolled the time to appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does a Rule 60(a) motion toll the appeal period if filed within 28 days of judgment?	State: Rule 60(a) correction does not toll; appeal is untimely	Father: Filing tolled appeal period; appeal is timely	Yes; under current rule, any timely Rule 60 motion tolls the appeal period, including 60(a).
Should appeal be dismissed for lack of jurisdiction?	Yes, for untimeliness	No, it was filed on time	No; court has jurisdiction because appeal was timely under the rules as amended.

State v. Champlain Cable Corp., 147 Vt. 436 (prior rule: Rule 60(a) corrections did not toll appeal period; now superseded by rule change)
In re Hamid-Ahmed, 208 Vt. 536 (plain meaning of rules must be enforced)
Grantham v. Ohio Cas. Co., 97 F.3d 434 (federal interpretation: post-amendment Rule 60 motions toll appeal period)