In re D.P

In In re D.P., 147 Vt. 26, 510 A.2d 967 (1986), the Court explained that if the juvenile court denies parent-child contact pending an appeal from an order terminating parental rights, and the order is later reversed by the Court, the lack of contact pending appeal cannot be used against the parent in a later termination proceeding. 147 Vt. at 33, 510 A.2d at 971. That decision precludes the court from using its denial of visitation against mother in determining whether to terminate her rights.