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Supreme Court of Vermont · 2015
In re M.M. and C.M., Juveniles, 133 A.3d 379 (Vt. 2015)
The majority affirmed a CHINS adjudication on a broader individualized record of inconsistent addiction treatment, illicit drug use, neonatal withdrawal, and dangerous conduct; it did not hold that prenatal smoking alone is sufficient. A separate concurrence and dissent warned against converting prenatal population-risk evidence into a per se child-welfare predicate.
Later courts cite it without significant positive or negative signal.
Treatment last confirmed August 19, 2026. Case-wide subsequent treatment; human-set. Not specific to any one passage.