Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 668 (2026)

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

(Cite as: 15 V.S.A. § 668)
Notes of Decisions
Cited in 76 cases (17 in the last 5 years), 1986–2026 · leading case: DeBeaumont v. Goodrich, 644 A.2d 843 (Vt. 1994).
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DeBeaumont v. Goodrich, 644 A.2d 843 (Vt. 1994). · cites it 12× “" 15 V.S.A. § 668. Once that threshold is met, the moving party must then show that annulling, varying or modifying a prior parental rights and responsibilities determination is in the *846 best interests of the child.”
Gazo v. Gazo, 697 A.2d 342 (Vt. 1997). · cites it 8× “We hold that the family court exceeded its authority in defining a relocation as a change of circumstances for the purpose of retaining jurisdiction under 15 V.S.A. § 668, and that other provisions of its order dealing with parental decision-making and visitation are overbroad…”
Spaulding v. Butler, 782 A.2d 1167 (Vt. 2001). · cites it 6× “Mother argues that the court erred in finding that a real, substantial and unanticipated change of circumstances had occurred, see 15 V.S.A. § 668, and in concluding that awarding custody to father was in Nathan's best interests.”
Heidi Corcoran Wener v. Erik Wener, 2016 VT 109 (Vt. 2016). · cites it 6× “Much of the difference in the positions of the parties in this case and the analysis of the trial court relate to the interaction of the statutory provisions and the agreement, with the grounds for modification of a court order based on a parental agreement governing parental…”
Knutsen v. CEGALIS, 2009 VT 110 (Vt. 2009). · cites it 6× “2d at 846 ; see also 15 V.S.A. § 668 (providing that a court may modify a custody order upon a showing of "real, substantial and unanticipated change of circumstances").”
Hoover (Letourneau) v. Hoover, 764 A.2d 1192 (Vt. 2000). · cites it 4× “In a decision dated December 18, 1998, after a hearing on the matter, the court concluded under 15 V.S.A. § 668 that mother's move to Connecticut constituted a real, substantial and unanticipated change of circumstances necessitating reconsideration and modification of the…”
DeLeonardis v. Page, 2010 VT 52 (Vt. 2010). · cites it 4× “Under the circumstances, and recognizing that the stipulation was filed after the dissolution order became final, we treat the parties’ filing as a joint motion to modify the dissolution order, governed by 15 V.S.A. § 668 and Vermont Rule for Family Proceedings 4(j).”
Maurer v. Maurer, 2005 VT 26 (Vt. 2005). · cites it 4× “15 V.S.A. § 668. There are no "fixed standards to determine what constitutes a substantial change in material circumstances"; instead, the court should be "guided by a rule of very general application that the welfare and best interests of the children are the primary concern in…”
DeSantis v. Pegues, 2011 VT 114 (Vt. 2011). · cites it 5× “However, the court concluded that there was sufficient evidence to support a finding of sexual abuse by a preponderance of evidence and then relied on this finding as evidence of “a real, unanticipated and substantial change in circumstances” sufficient to satisfy the threshold…”
Mullin v. Phelps, 647 A.2d 714 (Vt. 1994). · cites it 3× “The father argues that neither the one instance of sexual abuse that had allegedly taken place since the mother's last previous claim of abuse was rejected by the court, nor his failure to follow every aspect of the court's March 1992 order regarding therapy for him and the…”
Lane v. Schenck, 614 A.2d 786 (Vt. 1992). · cites it 4× “We must decide what standard applies in a proceeding brought under 15 V.S.A. § 668 (modification of custody) when, without agreement, a custodial parent decides to move a significant distance from the noncustodial parent.”
Hawkes v. Spence, 2005 VT 57 (Vt. 2005). · cites it 3× “See 15 V.S.A. § 668 (allowing court to modify previous divorce order upon showing of real, substantial and unanticipated change of circumstances, if it is in child’s best interests).”
Show all 76 citing cases →
— Vt. Stat. Ann. tit. 15, § 668(a) — 29 cases
Tracy McIntire Quinones v. Patrick C. Bouffard, 179 A.3d 173 (Vt. 2017).
Nicola Weaver v. David Weaver, 186 A.3d 1119 (Vt. 2018).
Alexandra Fox v. Nathan Fox, 2022 VT 27 (Vt. 2022).
Aron C. Vance v. Miranda Locke, 2022 VT 23 (Vt. 2022).
Michele L. Wright v. Dean J. Kemp, 207 A.3d 1021 (Vt. 2019).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.