15A V.S.A. § 2-402: Persons whose consent not required

(a) Consent to an adoption of a minor is not required of:

(1) a person who has relinquished parental rights or guardianship powers, including the right to consent to adoption, to an agency pursuant to this part of this article;

(2) a person whose parental relationship to the minor has been judicially terminated or determined not to exist;

(3) a man who has not been married to the woman who gave birth to the minor and who, after the conception of the minor, executes a notarized statement denying paternity or disclaiming any interest in the minor and acknowledging that his statement is irrevocable when executed;

(4) the personal representative of a deceased parent’s estate; or

(5) a parent or other person who has not executed a consent or a relinquishment and who fails to file an answer or make an appearance in a proceeding for adoption or for termination of a parental relationship within the requisite time after service of notice of the proceeding.

(b) The court may dispense with the consent of:

(1) a guardian or an agency whose consent is otherwise required upon a finding that the consent is being withheld unreasonably, contrary to the best interest of a minor adoptee; or

(2) a minor adoptee who has attained 14 years of age upon a finding that it is not in the best interest of the minor to require the consent.