Background
In June 2025, the family division found that Liam Edwards had abused Hayley Slayton and their minor daughter and that further abuse was threatened. It issued a final relief-from-abuse order granting Slayton sole possession of the parties’ residence, temporarily assigning her parental rights and responsibilities, and establishing Edwards’s parent-child-contact schedule. After Slayton filed for divorce, the court consolidated the proceedings and entered a temporary divorce order that retained her sole parental rights and responsibilities but adjusted Edwards’s contact schedule. A modified RFA order incorporated those changes.
Slayton later moved to extend the RFA order without changing the temporary parental-rights and contact provisions. Following a February 2026 hearing, the family division extended the RFA order for six months. Edwards appealed and primarily challenged the temporary contact schedule and a later interim child-support order. He also sought access to personal property at Slayton’s residence.
The Court’s Holding
The Vermont Supreme Court affirmed the extension. It held that the temporary parent-child-contact order was interlocutory and therefore not appealable as of right. The interim child-support order was likewise outside the appeal’s scope because it was interlocutory and was entered after Edwards filed his notice of appeal.
The Court could not review any challenge to the RFA extension because Edwards had not ordered a transcript of the extension hearing. Without that transcript, the Court could not assess the family division’s reasons for finding an extension necessary under 15 V.S.A. § 1103(e). It also declined to consider Edwards’s request for access to personal property because modification of an RFA order must first be sought in the trial court, and Edwards did not show that he had preserved the issue below.
Key Takeaways
- Temporary parental-rights and parent-child-contact orders generally are interlocutory and not appealable as of right.
- An appellant who fails to order a necessary hearing transcript waives issues that require the transcript for informed appellate review.
- A party seeking to modify a final RFA order must first present the request to the trial court and preserve the issue for appeal.
Why It Matters
The decision underscores that appellate review in family cases depends on finality, an adequate record, and preservation. Even a self-represented appellant must supply the transcript needed to review a discretionary RFA extension and must first raise modification requests in the trial court.