In re H.A., Juvenile

Summary

The Supreme Court of Vermont affirmed a district court order terminating the residual parental rights of both parents of an eleven-year-old child adjudicated CHINS. The court held that a technical failure to give advance notice that SRS would seek termination at the dispositional review did not violate due process because the parents learned of the termination request and its grounds months before the evidence closed and showed no prejudice. Limits placed on the mother's cross-examination of the SRS psychologist were within the trial court's sound discretion, and the absence of explicit findings of a substantial change in material circumstances was not reversible where the findings were replete with facts meeting the required standard. The court further held that ample parent-specific findings supported termination of each parent's rights under the clear-and-convincing-evidence standard.