essential elements doctrine (Vermont) · Go Syfert
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essential elements doctrine in Vermont

8 Vermont opinions name it 2 courts 2003–2026 1 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 (3)

CaseFollowedCited
Preston v. Chabotgreen
vt · 1980 · cited in 1 Vermont opinions naming this issue, 2020–2020
1 sentence

2020See id. (observing burden of establishing laches falls to the party asserting it). ¶ 14.

11
Gallipo v. City of Rutlandgreen
vt · 1994 · cited in 1 Vermont opinions naming this issue, 2010–2010
2 sentences

2010See Gallipo v. City of Rutland, 163 Vt. 83, 86 , 656 A.2d 635, 638 (1994) (“Summary judgment [is appropriate] if, after an adequate time for discovery, a party fails to make a showing sufficient to establish an essential element of the case on which the party will bear the burden of proof at trial.”). ¶28.

2010See Gallipo v. City of Rutland, 163 Vt. 83, 86 , 656 A.2d 635, 638 (1994) (“Summary judgment [is appropriate] if, after an adequate time for discovery, a party fails to make a showing sufficient to establish an essential element of the case on which the party will bear the burden of proof at trial.”). ¶28.

11
Harding v. Town of Townsendgreen
vt · 1871 · cited in 1 Vermont opinions naming this issue, 2008–2008
1 sentence

2008As we observed in Harding v. Town of Townshend, 43 Vt. 536, 539 (1871): “as between the insurer and the wrong-doer, .... [t]he party whose wrongful act or culpable negligence caused the injury ought to make compensation and bear the loss.” Thus, as courts and commentators have observed, one of the essential elements of the rule has always been its punitive nature.

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 (6)

CaseCitedYears
Chimel v. California red
scotus · 1969
2 sentences

2007Although its scope has varied over time, the essential elements of the doctrine were settled by the United States Supreme Court in the landmark case of Chimel v. California, 395 U.S. 752 , 89 S.Ct. 2034 , 23 L.Ed.2d 685 (1969).

2007Although its scope has varied over time, the essential elements of the doctrine were settled by the United States Supreme Court in the landmark case of Chimel v. California, 395 U.S. 752 (1969).

22007–2007
Gary Margolis v. Daily Direct LLC green
vt · 2023
1 sentence

2026Reg’ Ctr., 2019 VT 71A, Jf 59-60, 212 Vt. 612 ; (2) plaintiff's performance or a showing of a willingness and ability to perform the plaintiff's contractual obligations, see Margolis v. Daily Direct, LLC, 2023 VT 20 , 7 8, 218 Vt. 31 ; (3) breach by the defendant, see Beldock v. VWSD, LLC, 2023 VT 35 , {| 23-27, 218 Vt. 144 ; and (4) damages as a result of defendant’s breach, see Smith v. Country Vill.

12026–2026
Gregg Beldock v. VWSD, LLC green
vt · 2023
1 sentence

2026Reg’ Ctr., 2019 VT 71A, Jf 59-60, 212 Vt. 612 ; (2) plaintiff's performance or a showing of a willingness and ability to perform the plaintiff's contractual obligations, see Margolis v. Daily Direct, LLC, 2023 VT 20 , 7 8, 218 Vt. 31 ; (3) breach by the defendant, see Beldock v. VWSD, LLC, 2023 VT 35 , {| 23-27, 218 Vt. 144 ; and (4) damages as a result of defendant’s breach, see Smith v. Country Vill.

12026–2026
United States v. Armstrong green
scotus · 1996
1 sentence

2006The United States Supreme Court held that a defendant must provide “‘some evidence tending to show the existence of the essential elements of the defense,’ discriminatory effect and discriminatory intent.” 3 Armstrong, 517 U.S. at 468 (quoting Berrios, 501 F.2d at 1211 ).

12006–2006
United States v. Pablo Berrios green
ca2 · 1974
1 sentence

2006The United States Supreme Court held that a defendant must provide “‘some evidence tending to show the existence of the essential elements of the defense,’ discriminatory effect and discriminatory intent.” 3 Armstrong, 517 U.S. at 468 (quoting Berrios, 501 F.2d at 1211 ).

12006–2006
Tokarski v. Gates green
vt · 1980
1 sentence

2003Tokarski, 138 Vt. at 222 .

12003–2003

Where else courts name it

OH 192 (1978–2025) TX 143 (1937–2024) TN 107 (1976–2024) WA 101 (1961–2026) ID 70 (1955–2026) LA 53 (1938–2022) GA 50 (1935–2024) NC 48 (1978–2025) WY 44 (1979–2020) NY 42 (1894–2025) CA 42 (1920–2026) NM 31 (1971–2025) IL 31 (1971–2026) FL 30 (1942–2026) CT 28 (1963–2019) MO 26 (1957–2016) IN 25 (1972–2026) MS 24 (1995–2025) MA 23 (1991–2025) HI 20 (1995–2026) OR 19 (1984–2025) AL 18 (1923–2024) PA 17 (1926–2024) OK 16 (1911–2021) WV 14 (1987–2025) KY 13 (1949–2026) KS 12 (1953–2021) VA 12 (1988–2025) IA 11 (1935–2026) ME 10 (2011–2023) MI 10 (2014–2026) MD 9 (1923–2010) VT 8 (2003–2026) NJ 8 (1979–2025) ND 6 (1978–1996) DC 6 (1979–2003) AZ 6 (1936–1983) MN 5 (1972–2016) UT 5 (1994–2023) RI 5 (1987–2006) SC 4 (1932–2000) MT 4 (1989–2022) CO 3 (1988–2025) SD 3 (1992–2002) AK 3 (1991–2014) AR 3 (1998–2010)

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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