In re B.C., 81 A.3d 1152

B.C. was born in May 2004; a May 2006 parentage order gave mother sole rights and father visitation.
DCF repeatedly reported mother’s drug use, abuse of B.C., and involvement with sex offenders; care eventually entrusted to maternal grandfather, then maternal grandmother.
In May 2011 a probate court granted guardianship to the maternal grandmother.
B.C., age 7, displayed extreme aggression, sexualized remarks, and threats of suicide; he was diagnosed with PTSD and possibly Reactive Attachment Disorder and admitted to Baird Center in June 2011.
B.C. moved to a therapeutic foster home in Oct 2011 after hospitalizations and escalated behavior; DCF determined B.C. needed permanence and a stable, specialized environment; CHINS adjudication followed in Aug 2011.
Dispositions and permanency planning evolved toward eventual reunification with mother, with extensive services for both parents; father demonstrated limited insight and ability to meet B.C.’s needs; visits were suspended to aid placement transitions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether suspension of contact violated father’s fundamental rights	Father argues the suspension effectively terminated his rights without unfitness findings.	State contends the suspension was temporary, for safety, and not a permanent deprivation requiring a fitness finding.	Temporary suspension did not violate rights; no grounds to disturb termination.
Whether the court properly denied a request for an independent mental examination of B.C.	Father sought Rule 35 examination to assess father–child relationship.	State argued existing evaluations were sufficient and further examination could harm the child.	No abuse of discretion; no good cause shown for additional examination.
Whether the trial court’s findings were supported	Father challenges several findings as unsupported or in error.	State argues findings are supported by substantial evidence and credibility determinations.	Findings supported; no clear error given the credibility judgments and evidence.
Whether the best-interests determinations were correctly applied	Father contends different weighting or misapplication of § 5114 criteria.	State contends evidence shows B.C.’s needs require specialized care and permanent permanence.	Court did not abuse discretion; termination aligned with B.C.’s best interests given trauma and needs.

Mullin v. Phelps, 162 Vt. 250 (1994) (temporary deprivation not termination without fitness finding)
In re A.D., 143 Vt. 432 (1983) (clear and convincing standard governs permanent termination)
In re B.M., 165 Vt. 331 (1996) (reasonableness of time measured from child’s needs)
In re C.P., 2012 VT 100 (2012) (time to resume parenting measured by child’s needs; permanence important)
In re R.W., 2011 VT 124 (2011) (harmless-error standard in termination cases)
In re S.B., 174 Vt. 427 (2002) (standard of review for termination; credibility and weight of evidence)
In re K.F., 2004 VT 40 (2004) (deference to family court credibility determinations)
In re A.F., 160 Vt. 175 (1993) (policies governing parental rights and permanency)