preclusion doctrine (Vermont) · Go Syfert
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preclusion doctrine in Vermont

8 Vermont opinions name it 2 courts 2001–2025 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 (5)

CaseFollowedCited
In Re Application of Carriergreen
· 1990 · cited in 3 Vermont opinions naming this issue, 2015–2015
2 sentences

2015This preclusion doctrine provides that a local board “may not entertain a second application concerning the same property after a previous application has been denied, unless a substantial change of conditions had occurred or other considerations materially affecting the merits of the request have intervened between the first and second application.” In re Carrier, 155 Vt. 152, 158 , 582 A.2d 110, 113 (1990) (quotation omitted); see also In re Woodstock Cmty. Trust & Hous.

2015This preclusion doctrine provides that a local board “may not entertain a second application concerning the same property after a previous application has been denied, unless a substantial change of conditions had occurred or other considerations materially affecting the merits of the request have intervened between the first and second application.” In re Carrier, 155 Vt. 152, 158 , 582 A.2d 110, 113 (1990) (quotation omitted); see also In re Woodstock Cmty. Trust & Hous.

33
Mckenna v. Wrightgreen
ca2 · 2004 · cited in 2 Vermont opinions naming this issue, 2013–2013
2 sentences

2013See McKenna v. Wright, 386 F.3d at 432 ; 18 C.

2013See McKenna v. Wright, 386 F.3d at 432 ; 18 C.

22
In re Burns Two-Unit Residential Building (Michael Long Appellants)green
vt · 2016 · cited in 1 Vermont opinions naming this issue, 2025–2025
1 sentence

2025Rather, it illustrates reluctance to apply a broad preclusion rule in a manner that would “require the exercise of a fruitless and duplicate appeal to require the zoning administrator to perform his ministerial duty.” Fairchild, 159 Vt. at 132 , 616 A.2d at 232 ; see Burns, 2016 VT 63, ¶ 14 .

11
Lamb v. Geovjiangreen
vt · 1996 · cited in 1 Vermont opinions naming this issue, 2006–2006
2 sentences

2006See Lamb v. Geovjian, 165 Vt. 375, 379-80 , 683 A.2d 731, 734-35 (1996).

2006See Lamb v. Geovjian, 165 Vt. 375, 379-80 , 683 A.2d 731, 734-35 (1996).

11
American Trucking Associations, Inc. v. Conwaygreen
vt · 1989 · cited in 1 Vermont opinions naming this issue, 2001–2001
2 sentences

2001See American Trucking Ass’ns, 152 Vt. at 370 , 566 A.2d at 1328 (claim preclusion is a “theory of estoppel”).

2001See American Trucking Ass’ns, 152 Vt. at 370 , 566 A.2d at 1328 (claim preclusion is a “theory of estoppel”).

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
In Re Central Vermont Public Service Corporation green
vt · 2001
2 sentences

2013Corp., 172 Vt. at 21 , we have substantial concerns about the “fairness” prong of the preclusion test in light of the fact that municipal land use review panels typically employ relaxed procedural and evidentiary rules, and are often composed of laypersons with limited, if any, legal training.

2013Corp., 172 Vt. at 21 , we have substantial concerns about the “fairness” prong of the preclusion test in light of the fact that municipal land use review panels typically employ relaxed procedural and evidentiary rules, and are often composed of laypersons with limited, if any, legal training.

22013–2013
Petition of Fairchild green
vt · 1992
2 sentences

2025Rather, it illustrates reluctance to apply a broad preclusion rule in a manner that would “require the exercise of a fruitless and duplicate appeal to require the zoning administrator to perform his ministerial duty.” Fairchild, 159 Vt. at 132 , 616 A.2d at 232 ; see Burns, 2016 VT 63, ¶ 14 .

2025Rather, it illustrates reluctance to apply a broad preclusion rule in a manner that would “require the exercise of a fruitless and duplicate appeal to require the zoning administrator to perform his ministerial duty.” Fairchild, 159 Vt. at 132 , 616 A.2d at 232 ; see Burns, 2016 VT 63, ¶ 14 .

12025–2025

Statutes the citing opinions construe

VT § Vt. Stat. Ann. tit. 10, § 6086 (4) VT § Vt. Stat. Ann. tit. 10, § 8504 (4) VT § Vt. Stat. Ann. tit. 24, § 4472 (4) VT § Vt. Stat. Ann. tit. 10, § 6083 (3) VT § Vt. Stat. Ann. tit. 24, § 4414 (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

CA 61 (1978–2026) AL 26 (1981–2010) NY 26 (1969–2017) AZ 17 (1988–2025) IL 16 (1984–2025) MI 12 (1996–2025) WI 11 (1991–2023) NM 8 (1988–2024) VT 8 (2001–2025) DC 7 (1986–2019) VA 7 (2001–2014) PA 7 (1984–2026) CT 7 (1990–2026) LA 6 (1994–2025) OK 6 (2002–2020) ID 5 (1985–2026) TX 4 (1985–2016) KS 4 (2003–2022) NJ 4 (1989–2002) DE 4 (2010–2019) OH 4 (1984–2017) MO 4 (1984–2016) GA 4 (1990–2020) OR 3 (1992–2022) RI 3 (1989–2000) CO 3 (1989–2013) WA 2 (2009–2009) UT 2 (1997–1997) IN 2 (2006–2006) TN 2 (2013–2016) ME 2 (2021–2022) NC 2 (2000–2004) WV 2 (1991–1991) WY 2 (1995–2017) IA 2 (1994–1997) MA 2 (1979–1989)

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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