Supreme Court of Vermont
In re S.B.L.
August 26, 1988150 Vt. 294
Summary
The Court affirmed the award of custody and guardianship to the biological father but reversed the denial of grandparent visitation. It held that an unwed biological father who has established a custodial, personal, or financial relationship with the child receives constitutional parental protection, requiring proof of statutory grounds before a nonparent may obtain guardianship or custody. The Court also held that the visitation decision lacked the required consideration and explanation under the grandparent-visitation statute and therefore required a remand for further proceedings.