In re B.M
In In re B.M., 165 Vt. 331, 342, 682 A.2d 477, 483 (1996), the father had never played a parental role in the child's life, but sought custody of her years after she had been placed in SRS custody.
The Court acknowledged the progress father had made in his personal life, but concluded that the family court's termination order was supported by its findings that:
(1) the child was not bonded with the father;
(2) the father had never been a primary caregiver to the child;
(3) because of incarcerations, the father had been absent for long periods of time when the child was young;
(4) the child did not feel safe in the father's presence because of past incidents of domestic abuse;
(5) the child expressed great anxiety at the possibility of reunification with her father. Id. at 340-42, 682 A.2d at 482-83.