In Re ME, 15 A.3d 112

May 25, 2008, petitioner's son P.L., 12, overdosed and was hospitalized after using multiple substances.
Petitioner discharged to petitioner's custody against medical advice with recommendations for intensive wraparound services and CHINS consideration if noncompliant.
DCF substantiated petitioner in August 2008 for placing P.L. at risk of harm due to failure to arrange a prompt drug/alcohol assessment.
Reviewer found petitioner delayed treatment for over ten weeks, despite DCF urging and hospital recommendations.
Board adopted the hearing officer's recommendation to reverse DCF's substantiation under an improper legal framework.
Court holds registry substantiation is independent of CHINS petitions and remands for proper factual findings and application of the correct standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CHINS filing is required for registry substantiation	DCF: no requirement to file CHINS to substantiate	Board: CHINS link governs substantiation	No; registry substantiation does not depend on CHINS petition.
Whether DCF's standard was misapplied by tying to CHINS or single egregious act	DCF argues proper statutory standard should apply (risk of harm independent of CHINS)	Board applied incorrect standard, conflating CHINS with registry	Remand to apply the correct statutory/policy standard.
Whether Board properly applied 33 V.S.A. § 4912 for substantiation	Substantiation supported by risk-of-harm criteria	Substantiation improperly broadened by policy	Remand for proper findings under correct statutory framework.

In re E.C., 2010 VT 50 (2010) (Board must apply law in effect for substantiation decisions)
In re Selivonik, 164 Vt. 383 (1995) (statutes governing registry are distinct from juvenile proceedings)
In re A.D., 143 Vt. 432 (1983) (two fundamental interests in state intervening in family neglect cases)
In re R.H., 2010 VT 95 (2010) (defines risk of harm and applies single egregious act policy)