Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 594 (2026)

✓ current as of May 2026
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Subchapter 003 : PROCEEDINGS GENERALLY

(Cite as: 15 V.S.A. § 594)
Notes of Decisions
Cited in 15 cases (3 in the last 5 years), 1978–2024 · leading case: Aron C. Vance v. Miranda Locke, 2022 VT 23 (Vt. 2022).
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Aron C. Vance v. Miranda Locke, 2022 VT 23 (Vt. 2022). · cites it 11× “15 V.S.A. § 594; V.R.F.P. 7. ¶ 23. Mother does not contest the trial court’s appointment of counsel for son in this case.”
Ihinger v. Ihinger, 2003 VT 38 (Vt. 2003). · cites it 2× “15 V.S.A. §§ 594, 669; V.R.F.P. 7. Under certain circumstances, the court may permit a child to be a wit *522 ness in the proceeding as well.”
Palmer v. Palmer, 416 A.2d 143 (Vt. 1980). · cites it 2× “He did not request that an attorney be appointed pursuant to 15 V.S.A. § 594 to represent the children's interest, cf.”
Michele L. Wright v. Dean J. Kemp, 207 A.3d 1021 (Vt. 2019). · cites it 2× “The family court may call a minor child as a witness in a proceeding concerning parental rights and responsibilities if it finds after hearing that the child's testimony is necessary to determining the custody issue, the probative value of the testimony outweighs the potential…”
Lumbra v. Lumbra, 394 A.2d 1139 (Vt. 1978). · cites it 2× “15 V.S.A. § 594. Upon final hearing, over objection of the plaintiff-appellant, the trial court allowed the children’s attorney to make a recommendation as to a *531 custody order.”
Davis v. Hunt, 704 A.2d 1166 (Vt. 1997). · cites it 3× “A threshold issue is whether the trial court’s apparent belief that the requirements of 15 V.S.A. § 594(b) applied was error. The statute establishes certain conditions for calling a child as a witness in a family proceeding.”
Lane v. Schenck, 614 A.2d 786 (Vt. 1992). “See 15 V.S.A. § 594(b) (“court shall appoint an attorney for a minor child before the minor child is called as a witness”).”
Berlin v. Berlin, 428 A.2d 1113 (Vt. 1981). · cites it 2× “He contends that the trial court abused its discretion by awarding custody without making findings concerning whether joint custody would be in the interest of the children,, and without appointing counsel to represent the interests of the children under 15 V.S.A. § 594. The…”
Rapp v. Dimino, 643 A.2d 835 (Vt. 1993). “§ 293 (desertion and support); see also 15 V.S.A. § 594 (court may appoint attorney to represent interest of children and may examine child in chambers); V.”
Putnam v. Putnam, 689 A.2d 446 (Vt. 1996). “E 7(b); see also 15 V.S.A. § 594(a) (“The court may appoint an attorney to represent the interest of a minor or dependent child with respect to child support and the allocation of parental rights and responsibilities.”
DeGrechie v. DeGrechie, 406 A.2d 385 (Vt. 1979). “He briefs claimed error in failure of the trial *374 court to appoint an attorney for the minor child in question under 15 V.S.A. § 594, and an in camera questioning of the minor child by the court in the absence of the parties’ attorneys.”
Katharine Davis v. Rama Davis, 2023 VT 21 (Vt. 2023). · cites it 6× “Specifically, 15 V.S.A. § 594(b) provides that the child who is the subject of a custody proceeding may only be called as a witness if the court finds after hearing that: (1) the child’s testimony is necessary to assist the court in determining the issue before it; (2) the…”
Show all 15 citing cases →
— Vt. Stat. Ann. tit. 15, § 594(a) — 2 cases
Aron C. Vance v. Miranda Locke, 2022 VT 23 (Vt. 2022). “15 V.S.A. § 594; V.R.F.P. 7. ¶ 23. Mother does not contest the trial court’s appointment of counsel for son in this case.”
Putnam v. Putnam, 689 A.2d 446 (Vt. 1996). “E 7(b); see also 15 V.S.A. § 594(a) (“The court may appoint an attorney to represent the interest of a minor or dependent child with respect to child support and the allocation of parental rights and responsibilities.”
— Vt. Stat. Ann. tit. 15, § 594(b) — 6 cases
Davis v. Hunt, 704 A.2d 1166 (Vt. 1997). “A threshold issue is whether the trial court’s apparent belief that the requirements of 15 V.S.A. § 594(b) applied was error. The statute establishes certain conditions for calling a child as a witness in a family proceeding.”
Lane v. Schenck, 614 A.2d 786 (Vt. 1992). “See 15 V.S.A. § 594(b) (“court shall appoint an attorney for a minor child before the minor child is called as a witness”).”
Ihinger v. Ihinger, 2003 VT 38 (Vt. 2003). “15 V.S.A. §§ 594, 669; V.R.F.P. 7. Under certain circumstances, the court may permit a child to be a wit *522 ness in the proceeding as well.”
Michele L. Wright v. Dean J. Kemp, 207 A.3d 1021 (Vt. 2019). “The family court may call a minor child as a witness in a proceeding concerning parental rights and responsibilities if it finds after hearing that the child's testimony is necessary to determining the custody issue, the probative value of the testimony outweighs the potential…”
Katharine Davis v. Rama Davis, 2023 VT 21 (Vt. 2023). “Specifically, 15 V.S.A. § 594(b) provides that the child who is the subject of a custody proceeding may only be called as a witness if the court finds after hearing that: (1) the child’s testimony is necessary to assist the court in determining the issue before it; (2) the…”
— Vt. Stat. Ann. tit. 15, § 594(c) — 2 cases
Michele L. Wright v. Dean J. Kemp, 207 A.3d 1021 (Vt. 2019). “The family court may call a minor child as a witness in a proceeding concerning parental rights and responsibilities if it finds after hearing that the child's testimony is necessary to determining the custody issue, the probative value of the testimony outweighs the potential…”
In Re Z.L., Juv. (Vt. Super. Ct. 2017).
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