Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 665 (2026)

✓ current as of May 2026
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Subchapter 003A : CHILD CUSTODY AND SUPPORT

(Cite as: 15 V.S.A. § 665)
Notes of Decisions
Cited in 166 cases (30 in the last 5 years), 1987–2026 · leading case: Cabot v. Cabot, 697 A.2d 644 (Vt. 1997).
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Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). · cites it 19× “§ 665(a), which states in part: "When the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent." As Tom and Ellen did not form an agreement to divide or share…”
Knutsen v. CEGALIS, 2009 VT 110 (Vt. 2009). · cites it 20× “[1] In reaching this decision, the court weighed the nine factors for determining the best interests of the child, 15 V.S.A. § 665, and found that, although both parties could provide quality care for the child, ultimately the balance favored an award to father when the child…”
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). · cites it 16× “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Shea v. Metcalf, 712 A.2d 887 (Vt. 1998). · cites it 18× “Mother contends that (1) the family court's order divides legal rights and responsibilities in a manner not permitted under 15 V.S.A. § 665(a), and (2) even if the statute authorizes such division, the family court abused its discretion in ordering the division and not awarding…”
Cloutier v. Blowers, 783 A.2d 961 (Vt. 2001). · cites it 12× “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Heidi Corcoran Wener v. Erik Wener, 2016 VT 109 (Vt. 2016). · cites it 11× “She argues that the court erred in finding a real, substantial, and unanticipated change in circumstances, and that the decision to modify the extant custody agreement was not in the best interests of the child as required by 15 V.S.A. § 665. We affirm the court’s finding of…”
Harris v. Harris, 546 A.2d 208 (Vt. 1988). · cites it 9× “§ 652 — the predecessor statute to 15 V.S.A. § 665 — did “not specifically require the [trial] court to give special weight to the fact that one party has acted as the primary caretaker of the child.”
Miller-Jenkins v. Miller-Jenkins, 2010 VT 98 (Vt. 2010). · cites it 8× “In accordance with 15 V.S.A. § 665(b), the court considered each of the nine statutory factors for determining parental rights and responsibilities with regard to IMJ.”
Nickerson v. Nickerson, 605 A.2d 1331 (Vt. 1992). · cites it 8× “When the relevant legal criteria, among them the eight factors set out in 15 V.S.A. § 665(b), are applied to the facts, it is important for the appellate court to know how the trial court weighed the facts and blended the standards to arrive at the conclusion.”
Andrew Alex Bratton v. Laura Holland (Bratton), 192 A.3d 1257 (Vt. 2018). · cites it 13× “While this case predated the enactment of 15 V.S.A. § 665, the controlling standard in Miles, and subsequently, has always been the best interests of the child.”
Chase v. Bowen, 2008 VT 12 (Vt. 2008). · cites it 6× “Under 15 V.S.A. § 665(a), “[w]hen the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent.”
Maurer v. Maurer, 2005 VT 26 (Vt. 2005). · cites it 6× “When the family court finds that there has been a real, substantial and unanticipated change of circumstances, it must consider if a change in parental responsibilities is in a child's best interests.”
Show all 166 citing cases →
— Vt. Stat. Ann. tit. 15, § 665(4) — 1 case
Moreau v. Sylvester, Sylvester v. Moreau, 2014 VT 31 (Vt. 2014).
— Vt. Stat. Ann. tit. 15, § 665(a) — 27 cases
Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). “§ 665(a), which states in part: "When the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent." As Tom and Ellen did not form an agreement to divide or share…”
Shea v. Metcalf, 712 A.2d 887 (Vt. 1998). “Mother contends that (1) the family court's order divides legal rights and responsibilities in a manner not permitted under 15 V.S.A. § 665(a), and (2) even if the statute authorizes such division, the family court abused its discretion in ordering the division and not awarding…”
Knutsen v. CEGALIS, 2009 VT 110 (Vt. 2009). “[1] In reaching this decision, the court weighed the nine factors for determining the best interests of the child, 15 V.S.A. § 665, and found that, although both parties could provide quality care for the child, ultimately the balance favored an award to father when the child…”
In Re the Marriage of Hansen, 733 N.W.2d 683 (Iowa 2007).
Chase v. Bowen, 2008 VT 12 (Vt. 2008). “Under 15 V.S.A. § 665(a), “[w]hen the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent.”
— Vt. Stat. Ann. tit. 15, § 665(b) — 98 cases
Miller-Jenkins v. Miller-Jenkins, 2010 VT 98 (Vt. 2010). “In accordance with 15 V.S.A. § 665(b), the court considered each of the nine statutory factors for determining parental rights and responsibilities with regard to IMJ.”
Harris v. Harris, 546 A.2d 208 (Vt. 1988). “§ 652 — the predecessor statute to 15 V.S.A. § 665 — did “not specifically require the [trial] court to give special weight to the fact that one party has acted as the primary caretaker of the child.”
Maurer v. Maurer, 2005 VT 26 (Vt. 2005). “When the family court finds that there has been a real, substantial and unanticipated change of circumstances, it must consider if a change in parental responsibilities is in a child's best interests.”
Cloutier v. Blowers, 783 A.2d 961 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Nickerson v. Nickerson, 605 A.2d 1331 (Vt. 1992). “When the relevant legal criteria, among them the eight factors set out in 15 V.S.A. § 665(b), are applied to the facts, it is important for the appellate court to know how the trial court weighed the facts and blended the standards to arrive at the conclusion.”
— Vt. Stat. Ann. tit. 15, § 665(b)(1) — 13 cases
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). “§ 665(a), which states in part: "When the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent." As Tom and Ellen did not form an agreement to divide or share…”
Andrew Alex Bratton v. Laura Holland (Bratton), 192 A.3d 1257 (Vt. 2018). “While this case predated the enactment of 15 V.S.A. § 665, the controlling standard in Miles, and subsequently, has always been the best interests of the child.”
Poulin v. Upham, 538 A.2d 181 (Vt. 1987).
Thompson v. Pafundi, 2010 VT 80 (Vt. 2010).
— Vt. Stat. Ann. tit. 15, § 665(b)(2) — 8 cases
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Habecker v. Giard, 2003 VT 18 (Vt. 2003).
Thompson v. Pafundi, 2010 VT 80 (Vt. 2010).
MacCormack v. MacCormack, 199 Vt. 233 (Vt. 2015).
Poulin v. Upham, 538 A.2d 181 (Vt. 1987).
— Vt. Stat. Ann. tit. 15, § 665(b)(3) — 12 cases
Nicola Weaver v. David Weaver, 186 A.3d 1119 (Vt. 2018).
Cloutier v. Blowers, 783 A.2d 961 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Heidi Corcoran Wener v. Erik Wener, 2016 VT 109 (Vt. 2016). “She argues that the court erred in finding a real, substantial, and unanticipated change in circumstances, and that the decision to modify the extant custody agreement was not in the best interests of the child as required by 15 V.S.A. § 665. We affirm the court’s finding of…”
Knutsen v. CEGALIS, 2009 VT 110 (Vt. 2009). “[1] In reaching this decision, the court weighed the nine factors for determining the best interests of the child, 15 V.S.A. § 665, and found that, although both parties could provide quality care for the child, ultimately the balance favored an award to father when the child…”
— Vt. Stat. Ann. tit. 15, § 665(b)(4) — 12 cases
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Shea v. Metcalf, 712 A.2d 887 (Vt. 1998). “Mother contends that (1) the family court's order divides legal rights and responsibilities in a manner not permitted under 15 V.S.A. § 665(a), and (2) even if the statute authorizes such division, the family court abused its discretion in ordering the division and not awarding…”
Tracy McIntire Quinones v. Patrick C. Bouffard, 179 A.3d 173 (Vt. 2017).
Hanson-Metayer v. Hanson-Metayer, 2013 VT 29 (Vt. 2013).
Moreau v. Sylvester, Sylvester v. Moreau, 2014 VT 31 (Vt. 2014).
— Vt. Stat. Ann. tit. 15, § 665(b)(5) — 18 cases
Knutsen v. CEGALIS, 2009 VT 110 (Vt. 2009). “[1] In reaching this decision, the court weighed the nine factors for determining the best interests of the child, 15 V.S.A. § 665, and found that, although both parties could provide quality care for the child, ultimately the balance favored an award to father when the child…”
Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). “§ 665(a), which states in part: "When the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent." As Tom and Ellen did not form an agreement to divide or share…”
Cloutier v. Blowers, 783 A.2d 961 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
DeBeaumont v. Goodrich, 644 A.2d 843 (Vt. 1994).
Bell v. Squires, 2003 VT 109 (Vt. 2003).
— Vt. Stat. Ann. tit. 15, § 665(b)(6) — 15 cases
Nickerson v. Nickerson, 605 A.2d 1331 (Vt. 1992). “When the relevant legal criteria, among them the eight factors set out in 15 V.S.A. § 665(b), are applied to the facts, it is important for the appellate court to know how the trial court weighed the facts and blended the standards to arrive at the conclusion.”
Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). “§ 665(a), which states in part: "When the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent." As Tom and Ellen did not form an agreement to divide or share…”
Maurer v. Maurer, 2005 VT 26 (Vt. 2005). “When the family court finds that there has been a real, substantial and unanticipated change of circumstances, it must consider if a change in parental responsibilities is in a child's best interests.”
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Varnum v. Varnum, 586 A.2d 1107 (Vt. 1990).
— Vt. Stat. Ann. tit. 15, § 665(b)(7) — 8 cases
Miller-Jenkins v. Miller-Jenkins, 2010 VT 98 (Vt. 2010). “In accordance with 15 V.S.A. § 665(b), the court considered each of the nine statutory factors for determining parental rights and responsibilities with regard to IMJ.”
Andrew Alex Bratton v. Laura Holland (Bratton), 192 A.3d 1257 (Vt. 2018). “While this case predated the enactment of 15 V.S.A. § 665, the controlling standard in Miles, and subsequently, has always been the best interests of the child.”
Harris v. Harris, 546 A.2d 208 (Vt. 1988). “§ 652 — the predecessor statute to 15 V.S.A. § 665 — did “not specifically require the [trial] court to give special weight to the fact that one party has acted as the primary caretaker of the child.”
Habecker v. Giard, 2003 VT 18 (Vt. 2003).
Thompson v. Pafundi, 2010 VT 80 (Vt. 2010).
— Vt. Stat. Ann. tit. 15, § 665(b)(8) — 5 cases
Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). “§ 665(a), which states in part: "When the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent." As Tom and Ellen did not form an agreement to divide or share…”
Shea v. Metcalf, 712 A.2d 887 (Vt. 1998). “Mother contends that (1) the family court's order divides legal rights and responsibilities in a manner not permitted under 15 V.S.A. § 665(a), and (2) even if the statute authorizes such division, the family court abused its discretion in ordering the division and not awarding…”
Nicola Weaver v. David Weaver, 186 A.3d 1119 (Vt. 2018).
Rogers v. Parrish, 923 A.2d 607 (Vt. 2007).
Rogers v. Parrish, 2007 VT 35 (Vt. 2007).
— Vt. Stat. Ann. tit. 15, § 665(b)(9) — 8 cases
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Chase v. Bowen, 2008 VT 12 (Vt. 2008). “Under 15 V.S.A. § 665(a), “[w]hen the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent.”
Hazlett v. Toomin, 2011 VT 73 (Vt. 2011).
Davis v. Hunt, 704 A.2d 1166 (Vt. 1997).
Jody LaFlam v. Diana LaFlam, 2022 VT 57 (Vt. 2022).
— Vt. Stat. Ann. tit. 15, § 665(b)(l) — 3 cases
Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). “§ 665(a), which states in part: "When the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent." As Tom and Ellen did not form an agreement to divide or share…”
Chase v. Bowen, 2008 VT 12 (Vt. 2008). “Under 15 V.S.A. § 665(a), “[w]hen the parties cannot agree to divide or share parental rights and responsibilities, the court shall award parental rights and responsibilities primarily or solely to one parent.”
Bell v. Squires, 2003 VT 109 (Vt. 2003).
— Vt. Stat. Ann. tit. 15, § 665(c) — 7 cases
Baker v. State, 744 A.2d 864 (Vt. 1999).
Cloutier v. Blowers, 783 A.2d 961 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). “Adoption of Inappropriate Rules Custody determinations are now governed by statute, 15 V.S.A. § 665. That statute requires that the family court be guided by the best interest of the child, id.”
Gilbert v. Gilbert, 664 A.2d 239 (Vt. 1995).
Harris v. Harris, 647 A.2d 309 (Vt. 1994).
— Vt. Stat. Ann. tit. 15, § 665(d) — 4 cases
Knutsen v. CEGALIS, 2009 VT 110 (Vt. 2009). “[1] In reaching this decision, the court weighed the nine factors for determining the best interests of the child, 15 V.S.A. § 665, and found that, although both parties could provide quality care for the child, ultimately the balance favored an award to father when the child…”
Heffernan v. Harbeson, 2004 VT 98 (Vt. 2004).
Kasper v. Kasper, 2007 VT 2 (Vt. 2007).
Kasper v. Kasper, 917 A.2d 463 (Vt. 2007).
— Vt. Stat. Ann. tit. 15, § 665(f) — 1 case
Charles Groves v. Tasaday Green, 2016 VT 106 (Vt. 2016).
— Vt. Stat. Ann. tit. 15, § 665(f)(2) — 1 case
Charles Groves v. Tasaday Green, 2016 VT 106 (Vt. 2016).
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