Whether the State of Vermont may apply the 'reasonable probability' harmless error standard in assessing due process error in a termination of parental rights proceeding, rather than the more stringent Chapman standard, and whether Vermont may collapse the determination of 'parental unfitness' into a general 'best interests of the child' analysis when terminating parental rights, rather than making that determination early in the case

QUESTION PRESENTED May the State of Vermont, along with a minority of other states, apply the “reasonable probability” harmless error standard in assessing due process error in a termination of parental rights proceeding, or must the more stringent Chapman standard, required in cases of constitutional error and employed by a majority of states, be applied. Further, may the State of Vermont collapse the determination of “parental unfitness” into a general “best interests of the child” analysis that applies when parental rights are terminated, or must it, like the majority of other states, make that determination early in the case so that parents may have an opportunity to seek reunification.