Vt. Stat. Ann. » Title 14 Chapter 111
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 14, § 2645 (2026)

Repealed. 2013, No. 170 (Adj. Sess.), § 6, eff. September 1, 2014.

✓ current as of May 2026
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Subchapter 002 : PERSONS FOR WHOM GUARDIANS APPOINTED

(Cite as: 14 V.S.A. § 2645)
Notes of Decisions
Cited in 11 cases, 1980–2015 · leading case: In re S.B.L., 553 A.2d 1078 (Vt. 1988).
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In re S.B.L., 553 A.2d 1078 (Vt. 1988). · cites it 7× “Subsequently, the grandfather applied to the probate court pursuant to 14 V.S.A. § 2645 to be appointed guardian of S.”
Boisvert v. Harrington, 796 A.2d 1102 (Vt. 2002). · cites it 6× “14 V.S.A. § 2645. 3 There are also express statutory provisions for the termination of a guardianship issued under § 2645(2) (when the parent is shown to be “incompetent or unsuitable”), see 14 V.”
Guardianship of H. L., 460 A.2d 478 (Vt. 1983). · cites it 3× “The judge thereupon ruled that appellant would be adequately protected if counsel were to serve solely in his capacity as her attorney. No guardian ad litem was appointed.”
Thompson v. Dewey's South Royalton, Inc., 733 A.2d 65 (Vt. 1999). “See 14 V.S.A. §§ 2645, 3060. Parents are the "joint guardians" of their children.”
In Re Cifarelli, 611 A.2d 394 (Vt. 1992). “von Albrecht temporary custody of Anabelle under 14 V.S.A. § 2645(1) (“the probate court may appoint a guardian of the minor .”
In Re Sbl, 553 A.2d 1078 (Vt. 1988). · cites it 7× “Subsequently, the grandfather applied to the probate court pursuant to 14 V.S.A. § 2645 to be appointed guardian of S.”
Congdon v. Auto. Club Ins., 816 A.2d 504 (Vt. 2002). “14 V.S.A. § 2645(l)-(4). In this case there was no indication in the record that Boffa had undertaken the responsibilities of a guardian, or that Boffa had supplanted his mother as guardian.”
Jackson v. Hendricks, 2005 VT 113 (Vt. 2005). “On appeal, the paternal grandmother conceded that the UCCJA applied and that Bermuda was a “state” for purposes of the Act, but she asserted that Vermont had continuing jurisdiction by virtue of the guardianship order.”
Matson Ex Rel. Kehoe v. Anctil, 979 F. Supp. 1031 (D. Vt. 1997). “” Vt. Stat. Ann. tit. 14, § 2645 (5) (1989).”
Rutherford Ex Rel. Rutherford v. Best, 421 A.2d 1303 (1980). · cites it 5× “In that case, the Court had the opportunity to interpret the statutory *61 predecessor to 14 V.S.A. § 2645. While the suitability provision of that statute was not directly in issue, the Court, in what can only be termed extensive and considered dicta, provided a narrowing…”
In re Guardianships of D.B., T.B. & B.B. (Vt. 2015). · cites it 3× “14 V.S.A. § 2645. In 2014, the statute was amended.”
— Vt. Stat. Ann. tit. 14, § 2645(1) — 2 cases
In Re Cifarelli, 611 A.2d 394 (Vt. 1992). “von Albrecht temporary custody of Anabelle under 14 V.S.A. § 2645(1) (“the probate court may appoint a guardian of the minor .”
Jackson v. Hendricks, 2005 VT 113 (Vt. 2005). “On appeal, the paternal grandmother conceded that the UCCJA applied and that Bermuda was a “state” for purposes of the Act, but she asserted that Vermont had continuing jurisdiction by virtue of the guardianship order.”
— Vt. Stat. Ann. tit. 14, § 2645(2) — 6 cases
In re S.B.L., 553 A.2d 1078 (Vt. 1988). “Subsequently, the grandfather applied to the probate court pursuant to 14 V.S.A. § 2645 to be appointed guardian of S.”
Guardianship of H. L., 460 A.2d 478 (Vt. 1983). “The judge thereupon ruled that appellant would be adequately protected if counsel were to serve solely in his capacity as her attorney. No guardian ad litem was appointed.”
Boisvert v. Harrington, 796 A.2d 1102 (Vt. 2002). “14 V.S.A. § 2645. 3 There are also express statutory provisions for the termination of a guardianship issued under § 2645(2) (when the parent is shown to be “incompetent or unsuitable”), see 14 V.”
In Re Sbl, 553 A.2d 1078 (Vt. 1988). “Subsequently, the grandfather applied to the probate court pursuant to 14 V.S.A. § 2645 to be appointed guardian of S.”
Rutherford Ex Rel. Rutherford v. Best, 421 A.2d 1303 (1980). “In that case, the Court had the opportunity to interpret the statutory *61 predecessor to 14 V.S.A. § 2645. While the suitability provision of that statute was not directly in issue, the Court, in what can only be termed extensive and considered dicta, provided a narrowing…”
— Vt. Stat. Ann. tit. 14, § 2645(4) — 1 case
Boisvert v. Harrington, 796 A.2d 1102 (Vt. 2002). “14 V.S.A. § 2645. 3 There are also express statutory provisions for the termination of a guardianship issued under § 2645(2) (when the parent is shown to be “incompetent or unsuitable”), see 14 V.”
— Vt. Stat. Ann. tit. 14, § 2645(B) — 1 case
Rutherford Ex Rel. Rutherford v. Best, 421 A.2d 1303 (1980). “In that case, the Court had the opportunity to interpret the statutory *61 predecessor to 14 V.S.A. § 2645. While the suitability provision of that statute was not directly in issue, the Court, in what can only be termed extensive and considered dicta, provided a narrowing…”
— Vt. Stat. Ann. tit. 14, § 2645(l) — 2 cases
Boisvert v. Harrington, 796 A.2d 1102 (Vt. 2002). “14 V.S.A. § 2645. 3 There are also express statutory provisions for the termination of a guardianship issued under § 2645(2) (when the parent is shown to be “incompetent or unsuitable”), see 14 V.”
Congdon v. Auto. Club Ins., 816 A.2d 504 (Vt. 2002). “14 V.S.A. § 2645(l)-(4). In this case there was no indication in the record that Boffa had undertaken the responsibilities of a guardian, or that Boffa had supplanted his mother as guardian.”
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