14 Vermont opinions name it 2 courts 1988–2025 3 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.
| Case | Followed | Cited |
|---|---|---|
In re H.A.green2 sentences2024In re H.A., 153 Vt. 504, 515 (1990) (explaining that “the changed circumstances test is met when the findings in the case are replete with facts sufficient to meet the required standard” (quotation omitted)). 2004See In re H.A., 153 Vt. 504, 515 , 572 A.2d 884, 890 (1990) (“the changed circumstances test is met when the findings in the case are replete with facts sufficient to meet the required standard”) (internal quotation marks and citation omitted). | 3 | 3 |
In Re HAgreen2 sentences2004See In re H.A., 153 Vt. 504, 515 , 572 A.2d 884, 890 (1990) (“the changed circumstances test is met when the findings in the case are replete with facts sufficient to meet the required standard”) (internal quotation marks and citation omitted). 2004See In re H.A., 153 Vt. 504, 515 , 572 A.2d 884, 890 (1990) ("the changed circumstances test is met when the findings in the case are replete with facts sufficient to meet the required standard") (internal quotation marks and citation omitted). | 2 | 4 |
In Re CLgreen2 sentences1993An explicit finding of changed circumstances is not required to uphold a modification order; “[r]ather, the changed circumstances test is met when the findings in the case are ‘replete with facts sufficient to meet the required standard.’” Id. at 515 , 572 A.2d at 890 (quoting In re C.L., 151 Vt. 480, 483 , 563 A.2d 241, 243-44 (1989)). 1993An explicit finding of changed circumstances is not required to uphold a modification order; "[r]ather, the changed circumstances test is met when the findings in the case are `replete with facts sufficient to meet the required standard.'" Id. at 515 , 572 A.2d at 890 (quoting In re C.L., 151 Vt. 480, 483 , 563 A.2d 241, 243-44 (1989)). | 2 | 4 |
In re C.L. & H.L.green2 sentences2025“This Court has never held that the absence of an explicit finding as to changed circumstances requires the reversal of a modification order,” and as long as the trial court makes sufficient findings to support the changed- circumstances standard, “we will not reverse the trial court’s disposition on a technicality.” In re C.L., 151 Vt. 480, 482-83 (1989). 1993An explicit finding of changed circumstances is not required to uphold a modification order; “[r]ather, the changed circumstances test is met when the findings in the case are ‘replete with facts sufficient to meet the required standard.’” Id. at 515 , 572 A.2d at 890 (quoting In re C.L., 151 Vt. 480, 483 , 563 A.2d 241, 243-44 (1989)). | 1 | 3 |
In Re Application of Carriergreen2 sentences2019See Armitage, 2006 VT 113, ¶ 4 (“The changed-circumstances requirement is satisfied when a revised proposal addresses all concerns that prevented approval of the prior application.” (citing Carrier, 155 Vt. at 159 )). 2006Id. at 159 , 582 A.2d at 114 . | 1 | 3 |
In re M.M.green1 sentence2023See In re M.M., 159 Vt. 517, 522 (1993) (noting that “the changed circumstances test is met when the findings in the case are replete with facts sufficient to meet the required standard” (quotation omitted)). | 1 | 1 |
In Re Armitagegreen1 sentence2019See Armitage, 2006 VT 113, ¶ 4 (“The changed-circumstances requirement is satisfied when a revised proposal addresses all concerns that prevented approval of the prior application.” (citing Carrier, 155 Vt. at 159 )). | 1 | 1 |
In Re Hildebrandgreen2 sentences2009Compare In re Dunkin Donuts, 2008 VT 139, ¶ 8 (noting that the successive- application doctrine applies to “zoning proceedings” generally and requiring its application in that case where a permit amendment—not a new application—was at issue) with In re Hildebrand, 2007 VT 5 , ¶¶ 12–13, 181 Vt. 568 (approving of the use of the changed circumstances doctrine when evaluating municipal permit amendment requests). 2009Compare In re Dunkin Donuts, 2008 VT 139, ¶ 8 (noting that the successive- application doctrine applies to “zoning proceedings” generally and requiring its application in that case where a permit amendment—not a new application—was at issue) with In re Hildebrand, 2007 VT 5 , ¶¶ 12–13, 181 Vt. 568 (approving of the use of the changed circumstances doctrine when evaluating municipal permit amendment requests). | 1 | 1 |
In Re Dunkin Donuts S.P. Approvalgreen2 sentences2009Compare In re Dunkin Donuts, 2008 VT 139, ¶ 8 (noting that the successive- application doctrine applies to “zoning proceedings” generally and requiring its application in that case where a permit amendment—not a new application—was at issue) with In re Hildebrand, 2007 VT 5 , ¶¶ 12–13, 181 Vt. 568 (approving of the use of the changed circumstances doctrine when evaluating municipal permit amendment requests). 2009Compare In re Dunkin Donuts, 2008 VT 139, ¶ 8 (noting that the successive- application doctrine applies to “zoning proceedings” generally and requiring its application in that case where a permit amendment—not a new application—was at issue) with In re Hildebrand, 2007 VT 5 , ¶¶ 12–13, 181 Vt. 568 (approving of the use of the changed circumstances doctrine when evaluating municipal permit amendment requests). | 1 | 1 |
Trezevant v. Trezevantgreen1 sentence1988Trezevant v. Trezevant, 403 A.2d 1134, 1137 (D.C. 1979) (footnote omitted). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Vermont. Read the followed side critically anyway. | ||
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.