Supreme Court of Vermont
In re L.M., Juvenile
February 14, 2014195 Vt. 637
Summary
The Vermont Supreme Court affirmed the trial court’s finding that L.M. is a child in need of care or supervision (CHINS), holding that although the admission of the mother’s out‑of‑court statements was erroneous, the error was harmless because sufficient admissible evidence supported the CHINS determination. The Court also rejected the father’s argument that placement with his mother negated the CHINS finding.
Holding
- Whether the trial court erred in admitting the mother’s out‑of‑court statements as admissions of a party‑opponent and, if so, whether such error was harmless.. The admission was erroneous, but the error was harmless because the State proved the CHINS finding by admissible evidence; therefore the trial court’s CHINS determination is affirmed.
Docket No. 13-355