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Vermont Supreme Court Reverses Denial of Stalking Protection Order

The Vermont Supreme Court reversed a trial court's denial of a relief-from-abuse order for Angela Ferrante, who alleged her former romantic partner Steven Adkins stalked her after their brief relationship that began on the Appalachian Trail ended due to his increasingly violent behavior.

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4 min readcourtlistener
Seal of the Supreme Court of Vermont

Case Information

Case No.:
25-AP-219

Key Takeaways

  • Vermont Supreme Court reversed trial court's denial of relief-from-abuse order
  • Relationship began on Appalachian Trail in late 2022, ended due to alleged violent behavior
  • Alleged stalking included physical threats, following victim, and online harassment
  • Case remanded for additional proceedings in family court

The Vermont Supreme Court reversed a lower court's denial of a relief-from-abuse order in a case involving alleged stalking that began with a romance on the Appalachian Trail.

In *Angela Ferrante v. Steven Adkins*, the state's highest court ruled that the Superior Court, Chittenden Unit, Family Division erred in denying Ferrante's request for protection from her former romantic partner. The appellate court remanded the case for additional proceedings.

Ferrante sought the relief-from-abuse order against Adkins in April 2024, alleging a pattern of stalking behavior that followed the end of their brief romantic relationship. According to court documents, the pair met while hiking the Appalachian Trail in late 2022 and began a short-term romantic relationship.

The relationship deteriorated as Ferrante became concerned about what she described as Adkins' "increasingly violent behavior," prompting her to end the relationship. Court records indicate that Ferrante testified about escalating incidents that caused her to fear for her physical safety, including threats Adkins made to injure himself and other hikers they were traveling with.

During the proceedings, Ferrante described specific acts of violence, including an incident where Adkins threw a gas canister at her. The situation escalated when Ferrante ended the relationship, with court testimony indicating she "ran away" from Adkins and contacted law enforcement after he followed her to a shelter and told her "she shouldn't feel safe."

The alleged harassment continued beyond their physical separation on the trail. Ferrante testified that Adkins posted disparaging information about her on a website used by Appalachian Trail hikers. The post allegedly included Ferrante's full name and portrayed her as "a danger to herself and others," according to court documents.

The case proceeded to a hearing that spanned three days across multiple months in 2024 and early 2025. The trial court heard testimony in May 2024, August 2024, and late February 2025 before ultimately denying Ferrante's request for the protective order.

Trial Judge Brian K. Valentine presided over the proceedings in the Family Division of the Superior Court. The specific grounds for the trial court's denial were not detailed in the available court documents, though the Vermont Supreme Court's reversal suggests the lower court may have applied incorrect legal standards or failed to properly weigh the evidence presented.

Relief-from-abuse orders in Vermont are designed to protect individuals from domestic violence, stalking, and other forms of abuse. The orders can include provisions requiring the alleged abuser to stay away from the petitioner's home, workplace, or other specified locations, and can also address contact restrictions and other protective measures.

The Vermont Supreme Court's decision to reverse and remand indicates that the appellate justices found sufficient legal or factual errors in the trial court's handling of the case to warrant a new review. The remand will require the lower court to conduct additional proceedings, which may include rehearing evidence or applying different legal standards to the facts presented.

The case highlights ongoing challenges in domestic violence and stalking proceedings, particularly in situations where relationships begin in unconventional settings like hiking trails. The Appalachian Trail, which stretches more than 2,100 miles from Georgia to Maine, attracts thousands of hikers annually, creating a unique social environment where relationships can form quickly among strangers sharing the challenging experience.

The use of hiking-related websites to post disparaging information about former partners represents a modern twist on traditional stalking behaviors, extending harassment into online communities that serve specific populations. Such conduct can be particularly damaging within tight-knit communities like long-distance hikers, where reputation and safety information are frequently shared among participants.

The Vermont Supreme Court's willingness to reverse the denial suggests the justices found the evidence of stalking behavior and threats sufficiently concerning to warrant protection. The court's brief entry order did not elaborate on the specific legal reasoning behind the reversal, but the decision to remand rather than simply reverse indicates that additional fact-finding or legal analysis may be required.

The case returns to the trial court for further proceedings, where Judge Valentine or another family court judge will need to reconsider Ferrante's request for protection under the guidance provided by the appellate court's ruling. The outcome of those proceedings could establish important precedent for how Vermont courts evaluate stalking allegations that cross state lines and involve online harassment within specialized communities.

The decision comes as courts nationwide grapple with evolving forms of harassment and stalking that incorporate digital platforms and social media, requiring judges to apply traditional protective order statutes to increasingly complex fact patterns involving modern technology and online communities.

Topics

relief from abuse orderstalkingdomestic violenceonline harassmentappellate procedure

Original Source: courtlistener

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