In Re A.O. & I.O., Juveniles & in Re B.G. & E.G., Juveniles

2023 VT 54
CourtSupreme Court of Vermont
DecidedSeptember 29, 2023
Docket23-AP-124 & 23-AP-126
StatusPublished
Cited by4 cases

This text of 2023 VT 54 (In Re A.O. & I.O., Juveniles & in Re B.G. & E.G., Juveniles) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re A.O. & I.O., Juveniles & in Re B.G. & E.G., Juveniles, 2023 VT 54 (Vt. 2023).

Opinion

NOTICE: This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports. Readers are requested to notify the Reporter of Decisions by email at: JUD.Reporter@vermont.gov or by mail at: Vermont Supreme Court, 109 State Street, Montpelier, Vermont 05609-0801, of any errors in order that corrections may be made before this opinion goes to press.

2023 VT 54

Nos. 23-AP-124 & 23-AP-126

In re A.O. & I.O., Juveniles Supreme Court

In re B.G. & E.G., Juveniles On Appeal from Superior Court, Rutland Unit, Family Division

September Term, 2023

David A. Barra, J.

Sarah Star, Middlebury, for Appellant Mother.

Matthew Valerio, Defender General, Kerrie Johnson, Juvenile Defender, and Ri Marchessault, Law Clerk (On the Brief), Montpelier, for Appellant Father (23-AP-124).

Nicholas R. Battey, Rutland County Deputy State’s Attorney, and Arthur O. Brown (Legal Intern), Rutland, for Appellee State.

PRESENT: Reiber, C.J., Eaton, Carroll, Cohen and Waples, JJ.

¶ 1. REIBER, C.J. Mother appeals from the decisions of the family division of the

superior court finding her four minor children B.G., E.G., I.O., and A.O. to be children in need of

care or supervision (CHINS). Mother’s husband J.O., who is the father of I.O. and A.O., appeals

from the decisions concerning those children. We conclude that the CHINS determinations were

not supported by the court’s findings or the evidence, and therefore reverse the CHINS merits and

associated disposition orders. We also conclude that the court erred in permitting the dissemination of certain records from the CHINS proceedings to J.O. and his advocate in a separate

administrative appeal and reverse that order as well.

¶ 2. When this proceeding began, all four children were living with mother and J.O.

J.O. is the father of I.O., born in 2019, and A.O., born in 2021. Mother’s ex-husband is the father

of B.G., born in 2012, and E.G., born in 2015.

¶ 3. In August 2021, the State filed petitions alleging that B.G., E.G., A.O., and I.O.

were CHINS because they had been exposed to domestic violence between mother and J.O. and

mother had failed to take steps to protect them. The affidavits filed in support of the petitions

made the following allegations. In May 2021, after an incident in the home involving J.O. and

mother, she called her father-in-law seeking help, and he contacted police on her behalf. When

police arrived at the family’s home, mother reported to the responding officers that J.O. had been

drinking. Sensing that he might become violent, mother had tried to leave the home with the two

younger children. She put five-month-old A.O. in her car seat and was in the bathroom with I.O.,

who was then seventeen months old. J.O. entered the bathroom and cornered mother. He yanked

out a chunk of her hair and threw a full can of soda at her, striking her in the face. When police

arrived, J.O. had locked himself in the house and refused to come out. Mother told police that J.O.

had previously strangled her on several occasions. J.O. was arrested and charged with aggravated

domestic assault. B.G. and E.G. were not in the home at the time.

¶ 4. The incident was reported to the Department for Children and Families (DCF),

which assigned an investigator. Mother met with the DCF worker the day after the incident. She

agreed to enroll the older children, B.G. and E.G., in therapy, and to meet again later to complete

a safety plan. Mother subsequently declined to give the DCF worker access to the older children’s

therapy records, to complete a safety plan, or to allow the worker to interview the older children.

She told the DCF worker that there were no safety concerns for the children. The DCF worker

2 eventually spoke to B.G. and E.G. at the home of their paternal grandmother. The children

indicated that they felt unsafe around J.O. and said that mother had told them not to talk to DCF

about J.O. E.G. told the investigator that mother forced her to eat hot sauce and that J.O. force-

fed her. The petition alleged that mother and J.O. continued to have contact after the May 2021

incident even though J.O.’s criminal conditions of release prohibited contact.1

¶ 5. The court transferred custody of the children to DCF in an emergency care order.

Following a contested hearing, in October 2021, the court issued a temporary care order continuing

DCF custody. B.G. and E.G. were initially placed in the care of their paternal grandmother. In

January 2022, the court transferred custody of B.G. and E.G. to their biological father in a

conditional custody order. A.O. and I.O. were placed with their paternal grandfather until April

2022, when they were placed back with mother and J.O. under a trial reunification. They continued

to live with mother and J.O. at the time of the merits hearing.

¶ 6. In January 2023, after a contested merits hearing, the court issued orders

adjudicating all four children as CHINS. In addition to the facts alleged in the CHINS affidavit,

the court found that mother had reported to police after the May 2021 incident that J.O. had at

various times bloodied mother’s nose; punched her in the stomach, possibly causing her to lose a

pregnancy; and raped her. Mother was frightened by J.O.’s rages and feared that he would kill her

if she sought help. The abuse had gone on for about six months prior to the May 2021 incident.

Mother had created a safety plan with a safe word, but when she attempted to implement it during

the May 2021 incident, J.O. prevented her from leaving and “domestic violence occurred in the

presence of” A.O. and I.O. After the incident, mother stopped cooperating with police or DCF

and sought to vacate a relief-from-abuse order that she had obtained and to modify J.O.’s criminal

1 J.O. contests this allegation, and the family court did not appear to rely on it in the merits determination. It is undisputed that J.O.’s conditions were modified several times to allow him to have more contact with mother.

3 conditions to allow contact with her and the children. The court found that this conduct resembled

mother’s behavior before the May 2021 incident, when she had been too frightened to report abuse,

and that her behavior led to reasonable concerns that the children were being placed at risk. The

court found that witnessing domestic violence and being in the same household where such

violence occurs harms children. The court found that the children’s mental health, welfare, and

safety were endangered by the May 2021 incident of domestic violence and by mother’s

subsequent failure to engage with DCF in safety planning to protect herself and the children from

future harm. It concluded that the children were without proper parental care in August 2021 when

the petition was filed.

¶ 7. In March 2023, the court issued disposition orders continuing legal custody of A.O.

and I.O. with DCF and conditional custody of B.G. and E.G. with their father. Mother appealed

all four disposition orders, and J.O. appealed the orders as to A.O. and I.O. This Court consolidated

the appeals for argument and decision.

¶ 8. The primary argument raised by both mother and J.O. in these appeals is that the

court’s findings were insufficient to support its conclusion that the children were CHINS at the

time the petition was filed. They also argue that the court applied the wrong legal standard in its

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Bluebook (online)
2023 VT 54, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ao-io-juveniles-in-re-bg-eg-juveniles-vt-2023.