Vermont Case Commentaries

Legislative Cutbacks to Earned-Time Credits Are Not Subject to Procedural Due Process; Victim-Expectation Carveouts Survive Common Benefits Review

Date: Sep 18, 2026

Legislative Cutbacks to Earned-Time Credits Are Not Subject to Procedural Due Process; Victim-Expectation Carveouts Survive Common Benefits Review I. Introduction In Chavis Murphy v. Nicholas Deml...

Option-to-Purchase Contracts: No Implied Right to Delay Closing to Challenge a Contractually-Required MAI Appraisal; Appraisal-Critique Experts Must Satisfy V.R.E. 702

Date: Sep 5, 2026

Option-to-Purchase Contracts: No Implied Right to Delay Closing to Challenge a Contractually-Required MAI Appraisal; Appraisal-Critique Experts Must Satisfy V.R.E. 702 Introduction Jamaica Cottage...

Relief-from-Abuse Orders May Rest on Circumstantial Proof of Nonaccidental Injury and a Parent’s Acts or Omissions Failing to Protect a Child

Date: Sep 5, 2026

Relief-from-Abuse Orders May Rest on Circumstantial Proof of Nonaccidental Injury and a Parent’s Acts or Omissions Failing to Protect a Child Note on authority: This decision is an Entry Order issued...

No Due Process Error from Reasonable Trial Time Limits Absent Objection or Prejudice; Unsworn Post-Trial Submissions Properly Excluded

Date: Sep 5, 2026

No Due Process Error from Reasonable Trial Time Limits Absent Objection or Prejudice; Unsworn Post-Trial Submissions Properly Excluded 1. Introduction Bryan Hutcheson v. Haley Frano and Kenneth Frano...

Financial and Logistical Realities May Be Weighed in Out-of-State Parent-Child Contact—§ 650 “Maximum Contact” Does Not Eliminate Trial-Court Discretion

Date: Sep 5, 2026

Financial and Logistical Realities May Be Weighed in Out-of-State Parent-Child Contact—§ 650 “Maximum Contact” Does Not Eliminate Trial-Court Discretion 1. Introduction Karissa Lashley v. Jacob...

Termination of Parental Rights: A Loving Bond Does Not Override the Child’s Need for Permanency When Other Best-Interest Factors Favor Termination

Date: Sep 5, 2026

Termination of Parental Rights: A Loving Bond Does Not Override the Child’s Need for Permanency When Other Best-Interest Factors Favor Termination Introduction Case: In re R.W., Juvenile (C.H.,...

Intervenor Standing Limits: Neighbors Cannot Appeal PUC Exclusion of Municipal Recommendations in § 248a CPG Proceedings

Date: Sep 5, 2026

Intervenor Standing Limits: Neighbors Cannot Appeal PUC Exclusion of Municipal Recommendations in § 248a CPG Proceedings I. Introduction Case: In re Petition of Industrial Tower and Wireless LLC...

Post-Judgment Business Setbacks Are Not “Newly Discovered Evidence” Under VR.C.P. 60(b)(2) in Divorce; Attorney’s Fees May Be Awarded for Meritless Relitigation

Date: Sep 5, 2026

Post-Judgment Business Setbacks Are Not “Newly Discovered Evidence” Under VR.C.P. 60(b)(2) in Divorce; Attorney’s Fees May Be Awarded for Meritless Relitigation 1. Introduction Case: Alison Beckwith...

Tumultuous Conduct Under 13 V.S.A. § 1026a: Loud, Confrontational Door-and-Window Banging Supports Aggravated Disorderly Conduct

Date: Sep 5, 2026

Tumultuous Conduct Under 13 V.S.A. § 1026a: Loud, Confrontational Door-and-Window Banging Supports Aggravated Disorderly Conduct Introduction In State v. Carl Holcomb, Jr. (Vt. Sept. 4, 2026) (entry...

Impaired Breathing as “Serious Bodily Injury” Under Vermont’s Aggravated Domestic Assault Statute; No Plain Error in MPC-Style Recklessness Instruction

Date: Sep 5, 2026

Impaired Breathing as “Serious Bodily Injury” Under Vermont’s Aggravated Domestic Assault Statute; No Plain Error in MPC-Style Recklessness Instruction Case: State v. Kisha Parson (Vt. Sup. Ct.,...

Competency Exams Are Not a Sixth Amendment “Critical Stage”: Vermont Recognizes Trial-Court Discretion to Exclude Defense Counsel

Date: Sep 5, 2026

Competency Exams Are Not a Sixth Amendment “Critical Stage”: Vermont Recognizes Trial-Court Discretion to Exclude Defense Counsel 1. Introduction State v. Jordan Lawyer (2026 VT 42) is an...

Contested Attorney-Fee Requests Require an Evidentiary Record; Rule 54(d)(2)(D) Cannot Shift the Movant’s Burden

Date: Sep 5, 2026

Contested Attorney-Fee Requests Require an Evidentiary Record; Rule 54(d)(2)(D) Cannot Shift the Movant’s Burden 1. Introduction Joan Falcao v. Mitchel Richardson arises from a $16,000 loan...

Act 250 Jurisdiction Persists After Sustained Unpermitted Expansion Despite Later “Decoupling”; Stop-Work Orders Upheld When Economic Effects Are Considered

Date: Aug 29, 2026

Act 250 Jurisdiction Persists After Sustained Unpermitted Expansion Despite Later “Decoupling”; Stop-Work Orders Upheld When Economic Effects Are Considered 1. Introduction In Land Use Review Board...

Probation-Violation Detention in Vermont: Presumption of Incarceration and No Right to “Try” a Release Plan Under 28 V.S.A. § 301(4)

Date: Aug 29, 2026

Probation-Violation Detention in Vermont: Presumption of Incarceration and No Right to “Try” a Release Plan Under 28 V.S.A. § 301(4) 1. Introduction State v. Tyrin Smith (Vt. Sup. Ct. Aug. 28, 2026)...

Finality in Vermont Judicial Foreclosures: An Unappealed Foreclosure Decree Cannot Be Attacked via an Appeal from the Sale Confirmation Order

Date: Aug 28, 2026

Finality in Vermont Judicial Foreclosures: An Unappealed Foreclosure Decree Cannot Be Attacked via an Appeal from the Sale Confirmation Order Case: Colonial Savings, FA v. Adam Huntley Court: Supreme...

“Until Such Time” Means No HOA Assessments or Voting Rights for Developer-Owned Undeveloped Lots Absent Road and Sewer Extensions—Ambiguous Lot Schedules Require Factfinding

Date: Aug 28, 2026

“Until Such Time” Means No HOA Assessments or Voting Rights for Developer-Owned Undeveloped Lots Absent Road and Sewer Extensions—Ambiguous Lot Schedules Require Factfinding Introduction In Hawk...

Partial Case-Plan Compliance Does Not Bar Termination at Initial Disposition When the Parent Cannot Resume Parenting Within a Reasonable Time

Date: Aug 28, 2026

Partial Case-Plan Compliance Does Not Bar Termination at Initial Disposition When the Parent Cannot Resume Parenting Within a Reasonable Time Introduction Case: In re J.B. Jr., A.B., B.B., E.B.,...

Bourdeau Bros., Inc. v. St. Pierre (2026 VT 38) — Novation Requires Proof the Creditor Agreed to Release a Co-Obligor

Date: Aug 28, 2026

Novation Requires Proof the Creditor Clearly Agreed to Release a Co-Obligor (and Unpreserved Equitable Claims Stay Waived) Case: Bourdeau Bros., Inc. v. Melissa St. Pierre and Jason St. Pierre, 2026...

In re D.P.: “Support” Is Not “Treatment,” and Parental Stagnation (Not Agency Friction) Justifies Post-Disposition Termination

Date: Aug 28, 2026

In re D.P.: “Support” Is Not “Treatment,” and Parental Stagnation (Not Agency Friction) Justifies Post-Disposition Termination 1. Introduction Case: In re D.P., Juvenile (Vt. Sup. Ct. Aug. 21, 2026)...

Actual Notice, Harmless Service Errors, and Late ICPC Requests Do Not Defeat Termination Where Parental Stagnation Persists

Date: Aug 28, 2026

Actual Notice, Harmless Service Errors, and Late ICPC Requests Do Not Defeat Termination Where Parental Stagnation Persists Decision: In re L.V., Juvenile (K.V., Mother* and J.S., Father*), Vermont...