Supreme Court of Vermont May 12, 1995, Nos. 94-190 & 94-489 (Gilbert v. Gilbert)

Johnson, J.

Today, we rule that the family court erred in relying on the written report of a guardian ad litem (GAL) that contained personal judgments and conclusions by third parties not contained in the record, when such report was objected to by a party and not admitted pursuant to the rules of evidence.