vested rights doctrine (Vermont) · Go Syfert
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vested rights doctrine in Vermont

12 Vermont opinions name it 2 courts 1991–2026 2 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 (5)

CaseFollowedCited
Smith v. Winhall Planning Commissiongreen
vt · 1981 · cited in 5 Vermont opinions naming this issue, 1991–2019
2 sentences

2019See In re Paynter 2-Lot Subdivision, 2010 VT 28, ¶ 9 , 187 Vt. 637 (citing Smith v. Winhall Planning Comm’n, 140 Vt. 178, 181-82 (1981)) (discussing the vested rights doctrine).

2010That persuasive import comes from the underlying rationale of the vested-rights doctrine, which is premised upon a desire in land use litigation to avoid “extended litigation” and “protracted maneuvering.” m, 140 Vt. at 182 .

15
In Re Handygreen
vt · 2000 · cited in 4 Vermont opinions naming this issue, 2006–2017
2 sentences

2017Id. at 344-47 , The legislature subsequently created a new exception to the vested rights doctrine, again calling for different treatment of municipal zoning permit applications when proposed changes to relevant parts of the zoning regulations are pending. 24 V.S.A. § 4449(d); Re: John A. Russell Corp., No. 1R0489-6-EB, Findings of Fact, Conclusions of Law, and Order at 28-29 (Vt.

2008In adopting this minority rule, the Vermont Supreme Court explained that it particularly fit a situation “where no amendment is pending at the time of the application”13 and that under this vested rights rule, the zoning proceedings must be “validly brought and pursued in good faith.” In re Handy, 171 Vt. 336, ¶ 22 (2000) (citing Smith, 140 Vt. at 182 ).

14
In Re Paynter 2-Lot Subdivisiongreen
vt · 2010 · cited in 1 Vermont opinions naming this issue, 2019–2019
2 sentences

2019See In re Paynter 2-Lot Subdivision, 2010 VT 28, ¶ 9 , 187 Vt. 637 (citing Smith v. Winhall Planning Comm’n, 140 Vt. 178, 181-82 (1981)) (discussing the vested rights doctrine).

2019See In re Paynter 2-Lot Subdivision, 2010 VT 28, ¶ 9 , 187 Vt. 637 (citing Smith v. Winhall Planning Comm’n, 140 Vt. 178, 181-82 (1981)) (discussing the vested rights doctrine).

11
In Re Appeal of Taft Corners Associates, Inc.green
vt · 2000 · cited in 1 Vermont opinions naming this issue, 2019–2019
1 sentence

2019Cf. Tafts Corners, 171 Vt. at 139-40, 758 A.2d at 809 (concluding that applicant who obtained subdivision permit before adverse regulatory change had no vested right in separate zoning permit which applicant sought after regulatory change). ¶ 41.

11
In Re Rossgreen
vt · 1989 · cited in 1 Vermont opinions naming this issue, 1991–1991
2 sentences

1991See In re Ross, 151 Vt. 54, 56-57 , 557 A.2d 490, 491-92 (1989).

1991See In re Ross, 151 Vt. 54, 56-57 , 557 A.2d 490, 491-92 (1989).

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 (3)

CaseCitedYears
In Re Wheeler Parcel Act 250 Determination (James M. Leas, Appellants) neutral
vt · 2025
1 sentence

2026“The vested-rights doctrine is a constitutional rule that a legislative body ‘cannot take away a right that has been vested by a social compact or by a court’s judgment.’” In re Wheeler Parcel Act 250 Determination, 2025 VT 28 , ¶ 9 n*6 (quoting “Vested-Rights Doctrine,” Black’s Law Dictionary (12th ed. 2024)).

12026–2026
In re Petition of Apple Hill Solar LLC (Libby Harris and Apple Hill Homeowners Association, Appellants) green
vt · 2019
1 sentence

2025Because the applicability of claim and issue preclusion are questions of law outside the Commission’s area of special expertise, “we review the question of whether [they] appl[y] without deference to the [Commission].” Apple Hill Solar LLC, 2019 VT 64, ¶ 22 . ¶ 47.

12025–2025
Preseault v. Wheel green
vt · 1974
2 sentences

1991Thus, it seeks to invoke the vested rights doctrine as developed in Preseault v. Wheel, 132 Vt. 247 , 315 A.2d 244 (1974), and Smith v. Winhall Planning Comm’n, 140 Vt. 178 , 436 A.2d 760 (1981).

1991Thus, it seeks to invoke the vested rights doctrine as developed in Preseault v. Wheel, 132 Vt. 247 , 315 A.2d 244 (1974), and Smith v. Winhall Planning Comm’n, 140 Vt. 178 , 436 A.2d 760 (1981).

11991–1991

Statutes the citing opinions construe

VT § Vt. Stat. Ann. tit. 10, § 6086 (4) VT § Vt. Stat. Ann. tit. 10, § 8504 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

WA 79 (1978–2025) CA 47 (1975–2026) IL 35 (1968–2021) NY 23 (1963–2026) PA 21 (1979–2026) ME 16 (2020–2025) TX 14 (2006–2021) VT 12 (1991–2026) MD 12 (1993–2024) OR 10 (2007–2019) NC 9 (1997–2025) DE 7 (2015–2022) NM 7 (1995–2010) MN 6 (1980–2016) KS 6 (1995–2018) NJ 5 (1993–2020) OH 5 (1990–2014) VA 4 (1996–2024) SD 3 (1992–2022) IA 3 (2009–2026) AK 3 (1968–1994) WI 3 (1995–2017) FL 3 (1967–2016) TN 3 (1995–2024) LA 2 (1970–2013) UT 2 (2005–2020) CT 2 (1986–2015) NV 2 (1984–1996) NH 2 (1980–1995) MI 2 (1977–1982) IN 2 (2007–2016) HI 2 (1982–2005)

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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