## Facts

- The parties married in 1989 and had a son in 1994; they separated in 1996 after the father disclosed an affair and sought a divorce.
- After separation, the mother stayed in the marital home with the child; the father moved in with a co-worker and her children.
- The mother restricted the father’s access to the child, leading the father to seek emergency and temporary visitation orders; a temporary visitation schedule was established in July 1996.
- The mother filed multiple relief-from-abuse petitions alleging physical and sexual abuse by the father; the family court found the allegations unsubstantiated and dismissed them.
- At the divorce trial, the family court found both parents were fit and had each provided appropriate care before separation.
- A court-appointed mental-health team reported the child interacted well with both parents but had been negatively affected by the mother’s interference with the father-child relationship.
- The family court awarded the mother sole legal and physical parental rights and responsibilities and granted the father extensive, structured visitation approaching equal time.
- The family court also divided the marital estate; the father appealed both the custody award and the property division.

## Issues

1. Whether the family court abused its discretion by awarding the mother sole legal and physical parental rights and responsibilities despite findings that she interfered with the father-child relationship and that both parents were fit custodial parents.
2. Whether the family court erred or abused its discretion in dividing the marital estate, including valuation and allocation of assets and debts.

## Decision

- The Vermont Supreme Court affirmed the award of sole legal and physical parental rights and responsibilities to the mother.
- The Court held the family court did not abuse its discretion in weighing the statutory best-interests factors, including evidence of interference and unsubstantiated abuse allegations.
- The Court affirmed the division of the marital estate as reasonable and supported by the record.
- Judgment affirmed.

## Legal Principles

- Custody determinations are reviewed for abuse of discretion; factual findings are upheld unless clearly erroneous when viewed in the light most favorable to the prevailing party.
- Interference with the other parent’s relationship and unsubstantiated abuse allegations are relevant to the best-interests analysis, but they are not automatically dispositive and do not require a per se change of custody.
- Trial courts may address conflict and interference by crafting visitation provisions that preserve the child’s stability while ensuring substantial ongoing contact with the noncustodial parent.
- Marital property divisions are reviewed deferentially; an appellate court will uphold a distribution that reflects consideration of statutory factors and is reasonable on the evidence.

## Conclusion

The Vermont Supreme Court upheld a custody order granting the mother sole legal and physical parental rights and responsibilities, concluding that the family court permissibly weighed the mother’s interference and unsubstantiated abuse allegations within a fact-specific best-interests analysis and mitigated harm through extensive visitation for the father; it also affirmed the marital property division as within the trial court’s broad discretion.


Renaud v. Renaud, 721 A.2d 463 (Vt. 1998)