Dillon rule (Vermont) · Go Syfert
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Dillon rule in Vermont

5 Vermont opinions name it 2 courts 1990–2011 0 in the last five years

The cases below were cited by Vermont courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Hinesburg Sand & Gravel Co. v. Town of Hinesburggreen
vt · 1977 · cited in 3 Vermont opinions naming this issue, 1990–2011
2 sentences

2011The Vermont legislature has adopted the “Dillon’s rule” scheme for the grant of municipal authority; that is, municipalities in Vermont have “only those powers and functions specifically authorized by the legislature, and such additional functions as may be incident, subordinate or necessary to the exercise thereof.” In re Petition of Ball Mountain Dam Hydroelectric Project, 154 Vt. 189, 192 (1990) (quoting Hinesburg Sand & Gravel Co. v. Town of Hinesburg, 135 Vt. 484, 486 (1977)).

2006HAT is correct that “[w]e have consistently adhered to the so-called Dillon’s rule that ‘a municipality has only those powers and functions specifically authorized by the legislature, and such additional functions as may be incident, subordinate or necessary to the exercise thereof.’ ” In re Ball Mountain Dam Hydroelectric Project, 154 Vt. 189, 192 , 576 A.2d 124, 126 (1990) (quoting Hinesburg Sand & Gravel Co. v. Town of Hinesburg, 135 Vt. 484, 486 , 380 A.2d 64, 66 (1977)).

33
In Re Ball Mountain Dam Hydroelectric Projectgreen
vt · 1990 · cited in 2 Vermont opinions naming this issue, 2006–2011
2 sentences

2011The Vermont legislature has adopted the “Dillon’s rule” scheme for the grant of municipal authority; that is, municipalities in Vermont have “only those powers and functions specifically authorized by the legislature, and such additional functions as may be incident, subordinate or necessary to the exercise thereof.” In re Petition of Ball Mountain Dam Hydroelectric Project, 154 Vt. 189, 192 (1990) (quoting Hinesburg Sand & Gravel Co. v. Town of Hinesburg, 135 Vt. 484, 486 (1977)).

2006HAT is correct that “[w]e have consistently adhered to the so-called Dillon’s rule that ‘a municipality has only those powers and functions specifically authorized by the legislature, and such additional functions as may be incident, subordinate or necessary to the exercise thereof.’ ” In re Ball Mountain Dam Hydroelectric Project, 154 Vt. 189, 192 , 576 A.2d 124, 126 (1990) (quoting Hinesburg Sand & Gravel Co. v. Town of Hinesburg, 135 Vt. 484, 486 , 380 A.2d 64, 66 (1977)).

22
Hunters, Anglers & Trappers Ass'n of Vermont, Inc. v. Winooski Valley Park Districtgreen
vt · 2006 · cited in 1 Vermont opinions naming this issue, 2009–2009
2 sentences

2009See Hunters, Anglers & Trappers Ass’n of Vt., Inc. v. Winooski Valley Park Dist., 2006 VT 82, ¶ 7 , 181 Vt. 12 , 913 A.2d 391 (“We have consistently adhered *15 to the so-called Dillon’s rule that a municipality has only those powers and functions specifically authorized by the legislature, and such additional functions as may be incident, subordinate or necessary to the exercise thereof.” (quotations omitted)).

2009See Hunters, Anglers & Trappers Ass’n of Vt., Inc. v. Winooski Valley Park Dist., 2006 VT 82, ¶ 7 , 181 Vt. 12 , 913 A.2d 391 (“We have consistently adhered *15 to the so-called Dillon’s rule that a municipality has only those powers and functions specifically authorized by the legislature, and such additional functions as may be incident, subordinate or necessary to the exercise thereof.” (quotations omitted)).

11
Hunters, Anglers & Trappers Assoc. of VT v. Winooski Valley Park Districtgreen
vt · 2006 · cited in 1 Vermont opinions naming this issue, 2009–2009
1 sentence

2009See Hunters, Anglers & Trappers Ass’n of Vt., Inc. v. Winooski Valley Park Dist., 2006 VT 82, ¶ 7 , 181 Vt. 12 , 913 A.2d 391 (“We have consistently adhered *15 to the so-called Dillon’s rule that a municipality has only those powers and functions specifically authorized by the legislature, and such additional functions as may be incident, subordinate or necessary to the exercise thereof.” (quotations omitted)).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Vermont. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Taylor v. National Life Insurance green
vt · 1993
1 sentence

2002In other words, it is not clear from Dillon’s brief how the promise of training foreclosed Jogbra from nevertheless terminating her either on an at-will basis or for cause. 1 Cf. Taylor, 161 Vt. at 471-72 , 652 A.2d at *10 475 (employee failed to demonstrate how enforcement of promise to provide timely evaluation would have foreclosed the elimination of his position based on economic necessity). ¶ 21.

12002–2002
Valcour v. Village of Morrisville green
· 1932
2 sentences

1990Dillon’s rule calls for a strict construction of municipal function: “[I]f any fair, reasonable, substantial doubt exists concerning this question it must be resolved against the [grant of power].” Valcour, 104 Vt. at 130 , 158 A. at 86 .

1990Dillon’s rule calls for a strict construction of municipal function: “[I]f any fair, reasonable, substantial doubt exists concerning this question it must be resolved against the [grant of power].” Valcour, 104 Vt. at 130 , 158 A. at 86 .

11990–1990

Where else courts name it

CA 33 (1975–2021) CT 16 (1976–2000) PA 8 (1952–2008) IL 8 (1976–2016) IA 8 (1965–2006) TX 7 (1980–2016) VA 6 (1998–2023) NC 6 (1989–2019) NY 5 (1984–2021) VT 5 (1990–2011) NM 5 (1983–2006) MS 5 (1998–2014) AK 4 (1986–2013) NE 4 (1985–2003) UT 4 (1988–2018) MD 3 (1975–1981) OH 3 (2002–2023) IN 3 (1986–2018) LA 2 (1994–2023) NJ 2 (1982–1994) MO 2 (1984–1990) SD 2 (2004–2022) OR 2 (1985–1986) NH 2 (2003–2023) WA 2 (1975–2020) AZ 2 (1978–2023) SC 2 (1997–2013)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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