In Re K.P. / in Re Adoption of K.P.

2026 VT 4
CourtSupreme Court of Vermont
DecidedFebruary 20, 2026
Docket25-AP-114 / 25-AP-134
StatusPublished

This text of 2026 VT 4 (In Re K.P. / in Re Adoption of K.P.) 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 K.P. / in Re Adoption of K.P., 2026 VT 4 (Vt. 2026).

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: Reporter@vtcourts.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.

2026 VT 4

Nos. 25-AP-114 & 25-AP-134

In re K.P. Supreme Court

On Appeal from Superior Court, Lamoille Unit, Family Division Caledonia Unit, Probate Division

In re Adoption of K.P. Lamoille Unit, Civil Division

November Term, 2025

Robert R. Bent, J. (Ret.) (Family Division); Annette Lorraine, J. (Probate Division); and Benjamin Battles, J. (Civil Division)

Kurt M. Hughes of Tarnelli & Hughes Family Law, PLLC, Burlington, for Appellants.

B. P., Pro Se, Johnson, Appellee.

PRESENT: Reiber, C.J., Eaton and Cohen, JJ., and Fenster and Thibault, Supr. JJ., Specially Assigned

¶ 1. REIBER, C.J. This appeal concerns parental rights to minor child K.P.

Petitioners, K.P.’s mother and her husband S.A., appeal the family division’s order denying their

petitions to terminate the parental rights of respondent, K.P.’s father, and to permit S.A. to adopt

K.P. Petitioners also appeal the civil division’s dismissal of their appeal from the family division’s

decision to that court. We conclude that the civil division correctly dismissed petitioners’ appeal

to that court for lack of jurisdiction and that the evidence supported the family division’s decision

denying the termination petition. We therefore affirm both decisions. I. Facts

¶ 2. In September 2019, the Lamoille family division issued a final order of divorce

awarding mother sole legal and physical rights and responsibilities to K.P. and providing that

father would have contact with K.P. twice a week. Mother subsequently married S.A. In May

2021, S.A. and mother filed a pro se petition in the Caledonia probate division to allow S.A. to

adopt K.P., who was then four years old. Father was not initially served with the petition, and

nothing occurred in the adoption case until August 2023, when mother filed a petition to terminate

father’s parental rights in the probate case and finally served father. At that point, the Caledonia

probate division appointed counsel for father. The following month, father filed pro se motions in

the Lamoille family division to enforce the final order on parent-child contact and to modify

parent-child contact to give him equal time with K.P.

¶ 3. The record shows that mother and S.A. retained their own counsel at around this

time. In November 2023, they moved to transfer the adoption proceeding to the Lamoille family

division and consolidate it with the existing family case. The Lamoille family division granted the

motion. The Caledonia probate division then dismissed the probate proceeding.

¶ 4. When the case was transferred to the Lamoille family division, the family division

granted father’s probate counsel’s request to withdraw. The family division appointed different

counsel for father in the consolidated case in March 2024. New counsel subsequently moved to

withdraw because father was not responding to her requests for information. At a hearing on the

motion, father testified that he had not been able to respond because he was in Maine dealing with

the death of his aunt. The court denied the request to withdraw but warned father that if he failed

to cooperate with counsel, it would consider him to have waived his right to counsel. 1 Father

subsequently cooperated with his court-appointed counsel.

1 In the final order denying mother and S.A.’s petition, the family division found that father lied when he told the court that he was unable to appear in person because his aunt died, because 2 ¶ 5. The family division held an evidentiary hearing on the consolidated matter over

two days in October 2024 and January 2025, following which it issued a written decision

containing the following findings.

¶ 6. Mother and father met in March 2015, when mother was thirty-one and father was

twenty-one. They married in June 2015. In August 2016, K.P. was born.

¶ 7. Just before meeting mother, father had enlisted in the Marine Corps. He began

experiencing seizures after falling from a training scaffolding. The Marine Corps did not believe

father’s reports of seizures and discharged him in August 2015. The court found, in part based on

mother’s testimony, that father experienced intermittent seizures through 2022, after which the

seizures stopped.

¶ 8. After father returned home to Vermont, he and mother rented a home in Morrisville.

He obtained various jobs but was not able to maintain employment. The court found that father’s

seizures affected his ability to work, although they were not the sole reason for his inability to stay

employed. Rather, the court found that father appeared to be depressed and that his struggles were

“more likely than not, attributable to mental health dysfunction of some type.”

¶ 9. After K.P.’s birth, the family moved repeatedly. They lived with mother’s parents

for a time. Mother was K.P.’s primary caregiver, although father did provide some care when K.P.

was an infant. Mother worked as a phlebotomist at a hospital. While she was at work, K.P. went

to daycare in Morrisville with mother’s sister.

¶ 10. Mother and father’s relationship deteriorated after K.P.’s birth. They argued about

father’s belief that mother was seeing other men. Father was often moody and would leave to stay

with his friends. The court found that father was “verbally volatile” toward mother, but she did

he admitted at trial that his aunt was still alive. However, the court concluded that this “failure of candor” did not affect its assessment of father’s parental fitness or desire to redevelop his relationship with K.P. 3 not report that he was violent. Father did not engage in substance abuse or criminal behavior. The

parties filed complaints for relief from abuse against each other in 2017. Mother did not pursue

her complaint and father’s was dismissed. Mother eventually asked father to leave their home

because he was not regularly employed or actively parenting K.P. and was difficult to be with.

¶ 11. In November 2018, mother met S.A. Mother filed for divorce in December 2018.

At that time, mother and father both lived in Morrisville.

¶ 12. Initially, mother and father had joint parental rights under a temporary order issued

in February 2019. Mother soon moved to modify the order due to father’s living situation. Father

lacked stable housing after he and mother separated. He lived in his car from April to December

2019. He worked for a lawn-care service and at a gas station. Mother’s court filings indicated that

at that time, father was seeing K.P. somewhat regularly.

¶ 13. In September 2019, the Lamoille family division issued a final order awarding sole

legal rights and responsibilities for K.P. to mother. Father was to have visits twice a week for four

hours. The order anticipated that father would pick K.P. up from daycare for the visits and return

him to daycare afterward. Father admitted that in September 2019, he was unable to provide more

care for K.P. due to his unstable living situation and work schedule. He also lacked a working

vehicle and did not obtain one until 2020.

¶ 14.

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2026 VT 4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-kp-in-re-adoption-of-kp-vt-2026.