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

Vt. Stat. Ann. tit. 14, § 2664 (2026)

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

(Cite as: 14 V.S.A. § 2664)
Notes of Decisions
Cited in 12 cases (2 in the last 5 years), 2000–2025 · leading case: In re C.B., Juv., 2020 VT 80 (Vt. 2020).
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In re C.B., Juv., 2020 VT 80 (Vt. 2020). · cites it 3× “(codified at 14 V.S.A. § 2664(a)(1)). The 2016 Act also eliminated the requirement that a child subject to permanent guardianship be at least twelve years old.”
In re D.G., 2006 VT 60 (Vt. 2006). · cites it 3× “See 14 V.S.A. § 2664(a) (court must find by clear and convincing evidence certain enumerated facts before issuing order for permanent guardianship).”
In re A.S., 764 A.2d 1188 (Vt. 2000). “), § 2 (codified at 14 V.S.A. § 2664(a)(2)) (requiring court to determine by clear and convincing evidence that neither returning child to parents nor adoption is reasonably likely before issuing an order for permanent guardianship).”
In re M.W., 933 A.2d 243 (Vt. 2007). · cites it 2× “14 V.S.A. § 2664. Among other factors, the court must specifically find that “[njeither returning the child to the parents nor adoption of the child is reasonably likely during the remainder of the child’s minority.”
In re Guardianship of S.O. (L.O. & T.O., Appellants), 2021 VT 89 (Vt. 2021). · cites it 2× “[a]n order of permanent guardianship pursuant to 14 V.S.A. § 2664”). 7 the statutory scheme allows a parent to “file a motion to terminate a guardianship at any time.”
In Re As, 764 A.2d 1188 (Vt. 2000). “), § 2 (codified at 14 V.S.A. § 2664(a)(2)) (requiring court to determine by clear and convincing evidence that neither returning child to parents nor adoption is reasonably likely before issuing an order for permanent guardianship).”
In re C.G., Juv. (Vt. 2013). · cites it 5× “In May 2012, the maternal grandmother filed a petition for permanent guardianship pursuant to 14 V.S.A. § 2664. The court held a hearing in January 2013, and shortly thereafter issued a written decision granting the petition.”
In Re Y.R., Juv. (Vt. 2025). · cites it 2× “[a]n order of permanent guardianship pursuant to 14 V.S.A. § 2664.”). Mother, father, DCF, and Y.”
In re T.F. & B.F., Juveniles (Vt. 2014). · cites it 2× “See 14 V.S.A. § 2664(a)(2) (stating as one of requirements for establishing permanent guardianship that court find by clear and convincing evidence that “[n]either returning the child to the parents nor adoption of the child is likely within a reasonable period of time”); In re…”
In Re Mw, 2007 VT 90 (Vt. 2007). · cites it 2× “14 V.S.A. § 2664. Among other factors, the court must specifically find that "[n]either returning the child to the parents nor adoption of the child is reasonably likely during the remainder of the child's minority.”
In re T.P., Juv. (Vt. 2013). “See 14 V.S.A. § 2664(a)(2) (requiring family court to find prior to ordering a permanent guardianship that “Neither returning the child to the parents nor adoption of the child is likely within a reasonable period of time”).”
In re C.P., Juv. (Vt. 2012). “See 14 V.S.A. § 2664(a)(1)-(2). Therefore, the court approved a permanency plan with the goal of reunification, but admonished mother that such reunification would first require mother to substantially improve her compliance in a number of areas.”
— Vt. Stat. Ann. tit. 14, § 2664(a) — 4 cases
In re D.G., 2006 VT 60 (Vt. 2006). “See 14 V.S.A. § 2664(a) (court must find by clear and convincing evidence certain enumerated facts before issuing order for permanent guardianship).”
In re Guardianship of S.O. (L.O. & T.O., Appellants), 2021 VT 89 (Vt. 2021). “[a]n order of permanent guardianship pursuant to 14 V.S.A. § 2664”). 7 the statutory scheme allows a parent to “file a motion to terminate a guardianship at any time.”
In re C.G., Juv. (Vt. 2013). “In May 2012, the maternal grandmother filed a petition for permanent guardianship pursuant to 14 V.S.A. § 2664. The court held a hearing in January 2013, and shortly thereafter issued a written decision granting the petition.”
In Re Y.R., Juv. (Vt. 2025). “[a]n order of permanent guardianship pursuant to 14 V.S.A. § 2664.”). Mother, father, DCF, and Y.”
— Vt. Stat. Ann. tit. 14, § 2664(a)(1) — 3 cases
In re C.B., Juv., 2020 VT 80 (Vt. 2020). “(codified at 14 V.S.A. § 2664(a)(1)). The 2016 Act also eliminated the requirement that a child subject to permanent guardianship be at least twelve years old.”
In re C.G., Juv. (Vt. 2013). “In May 2012, the maternal grandmother filed a petition for permanent guardianship pursuant to 14 V.S.A. § 2664. The court held a hearing in January 2013, and shortly thereafter issued a written decision granting the petition.”
In re C.P., Juv. (Vt. 2012). “See 14 V.S.A. § 2664(a)(1)-(2). Therefore, the court approved a permanency plan with the goal of reunification, but admonished mother that such reunification would first require mother to substantially improve her compliance in a number of areas.”
— Vt. Stat. Ann. tit. 14, § 2664(a)(2) — 8 cases
In re C.B., Juv., 2020 VT 80 (Vt. 2020). “(codified at 14 V.S.A. § 2664(a)(1)). The 2016 Act also eliminated the requirement that a child subject to permanent guardianship be at least twelve years old.”
In re D.G., 2006 VT 60 (Vt. 2006). “See 14 V.S.A. § 2664(a) (court must find by clear and convincing evidence certain enumerated facts before issuing order for permanent guardianship).”
In re A.S., 764 A.2d 1188 (Vt. 2000). “), § 2 (codified at 14 V.S.A. § 2664(a)(2)) (requiring court to determine by clear and convincing evidence that neither returning child to parents nor adoption is reasonably likely before issuing an order for permanent guardianship).”
In re M.W., 933 A.2d 243 (Vt. 2007). “14 V.S.A. § 2664. Among other factors, the court must specifically find that “[njeither returning the child to the parents nor adoption of the child is reasonably likely during the remainder of the child’s minority.”
In Re As, 764 A.2d 1188 (Vt. 2000). “), § 2 (codified at 14 V.S.A. § 2664(a)(2)) (requiring court to determine by clear and convincing evidence that neither returning child to parents nor adoption is reasonably likely before issuing an order for permanent guardianship).”
— Vt. Stat. Ann. tit. 14, § 2664(a)(3) — 1 case
In re C.B., Juv., 2020 VT 80 (Vt. 2020). “(codified at 14 V.S.A. § 2664(a)(1)). The 2016 Act also eliminated the requirement that a child subject to permanent guardianship be at least twelve years old.”
— Vt. Stat. Ann. tit. 14, § 2664(a)(3)(A) — 1 case
In re T.F. & B.F., Juveniles (Vt. 2014). “See 14 V.S.A. § 2664(a)(2) (stating as one of requirements for establishing permanent guardianship that court find by clear and convincing evidence that “[n]either returning the child to the parents nor adoption of the child is likely within a reasonable period of time”); In re…”
— Vt. Stat. Ann. tit. 14, § 2664(c) — 1 case
In re C.G., Juv. (Vt. 2013). “In May 2012, the maternal grandmother filed a petition for permanent guardianship pursuant to 14 V.S.A. § 2664. The court held a hearing in January 2013, and shortly thereafter issued a written decision granting the petition.”
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