Vt. Stat. Ann. » Title 15 Chapter 19
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 1031 (2026)

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(Cite as: 15 V.S.A. § 1031)
Notes of Decisions
Cited in 22 cases, 1982–2014 · leading case: In re C. P., 2012 VT 100 (Vt. 2012).
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In re C. P., 2012 VT 100 (Vt. 2012). · cites it 4× “15 V.S.A. § 1031(3). [3] Thus, our definition of proceeding controls for UCCJA purposes.”
In re R.W. & N.W., 2011 VT 124 (Vt. 2011). · cites it 4× “The UCCJA defines “custody proceeding” as including “proceedings in which a custody determination is one of several issues, such as an action for divorce or separation, and includes child neglect and dependency proceedings.”
In re B.C., 726 A.2d 45 (Vt. 1999). · cites it 3× “2d at 1290 , that SRS is not a “contestant” under the UCCJA, see 15 V.S.A. § 1031(1) (“contestant” is person, including parent, claiming custody or visitation rights with respect to child), we conclude that SRS may be considered “a person acting as a parent” under the UCCJA.”
In re D.T., 743 A.2d 1077 (Vt. 1999). · cites it 2× “Mother argues that, under the UCCJA, the family court did not have jurisdiction to proceed to the merits of the CHINS proceeding. The UCCJA specifically includes neglect and dependency proceedings, such as CHINS proceedings, under the definition of “custody proceedings.”
Miller-Jenkins v. Miller-Jenkins, 2006 VT 78 (Vt. 2006). “These cases rely on three rationales: (1) the UCCJA explicitly applies to “neglect and dependency proceedings,” 15 V.S.A. § 1031(3), and the PKPA, which was drafted to generally track the UCCJA, intentionally omitted that language, see L.”
Columb v. Columb, 633 A.2d 689 (Vt. 1993). · cites it 2× “” 15 V.S.A. § 1031(5); see also 28 U.S.C. § 1738A(b)(4) (essentially identical definition).”
Chick v. Chick, 596 S.E.2d 303 (N.C. Ct. App. 2004). “See 15 V.S.A. § 1031(5) (2004). 3 . Mother asserts father conceded Vermont did not have home state jurisdiction because (1) father’s 2 July 2002 filing does not expressly argue Vermont is the home state and (2) father’s 3 July 2002 filing states “while i[t] may be true that…”
Matthews v. Riley, 649 A.2d 231 (Vt. 1994). · cites it 2× “See 15 V.S.A. §§ 1031(5) (defining home state), 1032(a)(1) (home state jurisdiction).”
In re B.J.C., 540 A.2d 1047 (Vt. 1988). · cites it 3× “The court denied the motion, ruling that it had jurisdiction under either the JPA or the Uniform Child Custody Jurisdiction Act, 15 V.S.A. § 1031 et seq. (UCCJA). This appeal followed.”
Dalmer v. State, 811 A.2d 1214 (Vt. 2002). “See 15 V.S.A. § 1031(8) (under Uniform Child Custody Jurisdiction Act, physical custody means “actual possession and control”); State v.”
In re A.W., 2014 VT 32 (Vt. 2014). · cites it 2× “§ 1061(7); see also 15 V.S.A. § 1031(5) (repealed July 1, 2011).”
Jackson v. Hendricks, 2005 VT 113 (Vt. 2005). · cites it 3× “§ 1738A(b)(3), and a “modification” as “a custody or visitation determination which modifies, replaces, supersedes, or otherwise is made subsequent to, a prior custody or visitation determination concerning the same child, whether made by the same court or not,” id.”
Show all 22 citing cases →
— Vt. Stat. Ann. tit. 15, § 1031(1) — 2 cases
In re B.C., 726 A.2d 45 (Vt. 1999). “2d at 1290 , that SRS is not a “contestant” under the UCCJA, see 15 V.S.A. § 1031(1) (“contestant” is person, including parent, claiming custody or visitation rights with respect to child), we conclude that SRS may be considered “a person acting as a parent” under the UCCJA.”
In Re Bc, 726 A.2d 45 (Vt. 1999).
— Vt. Stat. Ann. tit. 15, § 1031(3) — 9 cases
In re C. P., 2012 VT 100 (Vt. 2012). “15 V.S.A. § 1031(3). [3] Thus, our definition of proceeding controls for UCCJA purposes.”
In re R.W. & N.W., 2011 VT 124 (Vt. 2011). “The UCCJA defines “custody proceeding” as including “proceedings in which a custody determination is one of several issues, such as an action for divorce or separation, and includes child neglect and dependency proceedings.”
Miller-Jenkins v. Miller-Jenkins, 2006 VT 78 (Vt. 2006). “These cases rely on three rationales: (1) the UCCJA explicitly applies to “neglect and dependency proceedings,” 15 V.S.A. § 1031(3), and the PKPA, which was drafted to generally track the UCCJA, intentionally omitted that language, see L.”
In re B.C., 726 A.2d 45 (Vt. 1999). “2d at 1290 , that SRS is not a “contestant” under the UCCJA, see 15 V.S.A. § 1031(1) (“contestant” is person, including parent, claiming custody or visitation rights with respect to child), we conclude that SRS may be considered “a person acting as a parent” under the UCCJA.”
In re D.T., 743 A.2d 1077 (Vt. 1999). “Mother argues that, under the UCCJA, the family court did not have jurisdiction to proceed to the merits of the CHINS proceeding. The UCCJA specifically includes neglect and dependency proceedings, such as CHINS proceedings, under the definition of “custody proceedings.”
— Vt. Stat. Ann. tit. 15, § 1031(4) — 1 case
Jackson v. Hendricks, 2005 VT 113 (Vt. 2005). “§ 1738A(b)(3), and a “modification” as “a custody or visitation determination which modifies, replaces, supersedes, or otherwise is made subsequent to, a prior custody or visitation determination concerning the same child, whether made by the same court or not,” id.”
— Vt. Stat. Ann. tit. 15, § 1031(5) — 15 cases
In re C. P., 2012 VT 100 (Vt. 2012). “15 V.S.A. § 1031(3). [3] Thus, our definition of proceeding controls for UCCJA purposes.”
In re R.W. & N.W., 2011 VT 124 (Vt. 2011). “The UCCJA defines “custody proceeding” as including “proceedings in which a custody determination is one of several issues, such as an action for divorce or separation, and includes child neglect and dependency proceedings.”
Columb v. Columb, 633 A.2d 689 (Vt. 1993). “” 15 V.S.A. § 1031(5); see also 28 U.S.C. § 1738A(b)(4) (essentially identical definition).”
Chick v. Chick, 596 S.E.2d 303 (N.C. Ct. App. 2004). “See 15 V.S.A. § 1031(5) (2004). 3 . Mother asserts father conceded Vermont did not have home state jurisdiction because (1) father’s 2 July 2002 filing does not expressly argue Vermont is the home state and (2) father’s 3 July 2002 filing states “while i[t] may be true that…”
Matthews v. Riley, 649 A.2d 231 (Vt. 1994). “See 15 V.S.A. §§ 1031(5) (defining home state), 1032(a)(1) (home state jurisdiction).”
— Vt. Stat. Ann. tit. 15, § 1031(8) — 1 case
Dalmer v. State, 811 A.2d 1214 (Vt. 2002). “See 15 V.S.A. § 1031(8) (under Uniform Child Custody Jurisdiction Act, physical custody means “actual possession and control”); State v.”
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