host factors in Vermont

2015Also relevant . . . is the extent to which a party unjustifiably may have been excluded from the college decision-making process.” Mandel v. Mandel , 906 N.E.2d 1016, 1022 (Mass. Ct. App. 2009) (quotations and alterations omitted); see also Hathaway , 98 S.W.3d at 680 (noting that the “majority view” is that court must “determin[e] whether the child’s choice of college is reasonable,” considering child’s needs, parent’s ability to pay, and cost of tuition). ¶ 36.

2015Also relevant ... is the extent to which a party unjustifiably may have been excluded from the college decision-making process.” Mandel v. Mandel, 906 N.E.2d 1016, 1022 (Mass. App. Ct. 2009) (quotations and alterations omitted); see also Hathaway, 98 S.W.3d at 680 (noting that the “majority view” is that court must “determin[e] whether the child’s choice of college is reasonable,” considering child’s needs, parent’s ability to pay, and cost of tuition). ¶ 36.

2015Also relevant . . . is the extent to which a party unjustifiably may have been excluded from the college decision-making process.” Mandel v. Mandel , 906 N.E.2d 1016, 1022 (Mass. Ct. App. 2009) (quotations and alterations omitted); see also Hathaway , 98 S.W.3d at 680 (noting that the “majority view” is that court must “determin[e] whether the child’s choice of college is reasonable,” considering child’s needs, parent’s ability to pay, and cost of tuition). ¶ 36.

2015Also relevant ... is the extent to which a party unjustifiably may have been excluded from the college decision-making process.” Mandel v. Mandel, 906 N.E.2d 1016, 1022 (Mass. App. Ct. 2009) (quotations and alterations omitted); see also Hathaway, 98 S.W.3d at 680 (noting that the “majority view” is that court must “determin[e] whether the child’s choice of college is reasonable,” considering child’s needs, parent’s ability to pay, and cost of tuition). ¶ 36.

2014This Court explained, “We have held that the term ‘parent’ is specific to the context of the family involved.” Id .; see also Columbia v. Lawton , 2013 VT 2, ¶ 29 , 193 Vt. 165 , 71 A.3d 1218 (“The determination of an individual’s status, or potential status, as a parent requires consideration of a host of factors, including but not limited to a child’s genetic connection, or lack thereof, to a putative parent.”). ¶ 52.

2014This Court explained, “We have held that the term ‘parent’ is specific to the context of the family involved.” Id .; see also Columbia v. Lawton , 2013 VT 2, ¶ 29 , 193 Vt. 165 , 71 A.3d 1218 (“The determination of an individual’s status, or potential status, as a parent requires consideration of a host of factors, including but not limited to a child’s genetic connection, or lack thereof, to a putative parent.”). ¶ 52.

2012Although we do not generally require the trial court to articulate with specificity the reasons underlying its credibility determinations, State v. Hagen, 151 Vt. 64, 65 , 557 A.2d 493, 494 (1989), we *524 have recognized that a witness’s “demeanor, mannerisms, and tone of voice” as well as “a judge’s discretion and experience,” are all factors that are relevant to a trial court’s credibility determination.

2012Although we do not generally require the trial court to articulate with specificity the reasons underlying its credibility determinations, State v. Hagen, 151 Vt. 64, 65 , 557 A.2d 493, 494 (1989), we *524 have recognized that a witness’s “demeanor, mannerisms, and tone of voice” as well as “a judge’s discretion and experience,” are all factors that are relevant to a trial court’s credibility determination.

2012The two most important of these factors are “the overall strength of the State’s case without the offending evidence and the strength of the offending evidence.” Id.; see also Lipka, 174 Vt. at 385 , 817 A.2d at 34 . ¶ 42.

2012The two most important of these factors are “the overall strength of the State’s case without the offending evidence and the strength of the offending evidence.” Id.; see also Lipka, 174 Vt. at 385 , 817 A.2d at 34 . ¶ 42.

2012Our harm calculus is guided by a host of factors including: “the importance of the witness’ testimony in the prosecution’s case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of the cross-examination otherwise permitted, and, of course, the overall strength of the prosecution’s case.” Oscarson, 2004 VT 4, ¶ 32 (quotation omitted).