Vermont Statutes Annotated

Vt. Stat. Ann. tit. 33, § 5321 (2026)

✓ current as of May 2026
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(Cite as: 33 V.S.A. § 5321)
Notes of Decisions
Cited in 9 cases (3 in the last 5 years), 2012–2026 · 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 3× “” 33 V.S.A. § 5321(h). This can include efforts towards reunification or an alternate permanent living arrangement, depending on the goals of the permanency plan.”
In re D.F., H.F., M.F. & D.F., Juveniles, 204 A.3d 641 (Vt. 2018). · cites it 2× “33 V.S.A. § 5321(h). The statute provides that “[r]easonable efforts to finalize a permanency plan may consist of: (1) reasonable efforts to reunify the child and family following the child’s removal from the home, where the permanency plan for the child is reunification; or (2)…”
In re D.C., Juv., 2012 VT 108 (Vt. 2012). “Termination of parental rights may be granted at the initial disposition stage if the court determines that it is in the best interests of the child, as set forth in the statutory factors.”
In re C.L., Juv., 2021 VT 66 (Vt. 2021). “Until a child is adopted, the family court is required to review the case at regularly scheduled permanency hearings, 33 V.S.A. § 5321, and may issue protective orders if necessary, id.”
In re J.M., 127 A.3d 921 (Vt. 2015). “and creates uncertainty about his future. ¶ 20. In evaluating the evidence under the statutorily stated “best interests of the child” factors, id.”
In re Guardianship of S.O. (L.O. & T.O., Appellants), 2021 VT 89 (Vt. 2021). “, 2020 VT 80, ¶ 16 ; see also 33 V.S.A. § 5321 (providing that “[u]nless otherwise specified therein, an order .”
In re J.M., Juv., 2015 VT 94 (Vt. 2015). “¶ 20. In evaluating the evidence under the statutorily stated “best interests of the child” factors, id.”
In Re I.G., Juv. (Vt. 2026). “As we have previously explained in response to similarly framed arguments, the reasonable-efforts determination required by 33 V.S.A. § 5321(h) is separate from the decision to terminate parental rights, “and the former is not a prerequisite to the latter.”
In re T.P., Juv. (Vt. 2013). “); see 33 V.S.A. § 5321(a) (listing possible permanency goals).”
— Vt. Stat. Ann. tit. 33, § 5321(a) — 3 cases
In re J.M., 127 A.3d 921 (Vt. 2015). “and creates uncertainty about his future. ¶ 20. In evaluating the evidence under the statutorily stated “best interests of the child” factors, id.”
In re J.M., Juv., 2015 VT 94 (Vt. 2015). “¶ 20. In evaluating the evidence under the statutorily stated “best interests of the child” factors, id.”
In re T.P., Juv. (Vt. 2013). “); see 33 V.S.A. § 5321(a) (listing possible permanency goals).”
— Vt. Stat. Ann. tit. 33, § 5321(h) — 3 cases
In re C. P., 2012 VT 100 (Vt. 2012). “” 33 V.S.A. § 5321(h). This can include efforts towards reunification or an alternate permanent living arrangement, depending on the goals of the permanency plan.”
In re D.F., H.F., M.F. & D.F., Juveniles, 204 A.3d 641 (Vt. 2018). “33 V.S.A. § 5321(h). The statute provides that “[r]easonable efforts to finalize a permanency plan may consist of: (1) reasonable efforts to reunify the child and family following the child’s removal from the home, where the permanency plan for the child is reunification; or (2)…”
In Re I.G., Juv. (Vt. 2026). “As we have previously explained in response to similarly framed arguments, the reasonable-efforts determination required by 33 V.S.A. § 5321(h) is separate from the decision to terminate parental rights, “and the former is not a prerequisite to the latter.”
— Vt. Stat. Ann. tit. 33, § 5321(h)(2) — 1 case
In re C. P., 2012 VT 100 (Vt. 2012). “” 33 V.S.A. § 5321(h). This can include efforts towards reunification or an alternate permanent living arrangement, depending on the goals of the permanency plan.”
— Vt. Stat. Ann. tit. 33, § 5321(h)(l) — 1 case
In re D.C., Juv., 2012 VT 108 (Vt. 2012). “Termination of parental rights may be granted at the initial disposition stage if the court determines that it is in the best interests of the child, as set forth in the statutory factors.”
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