statutory construction rule (Vermont) · Go Syfert
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statutory construction rule in Vermont

7 Vermont opinions name it 2 courts 1995–2018 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 (3)

CaseFollowedCited
Langle v. Kurkulgreen
vt · 1986 · cited in 4 Vermont opinions naming this issue, 2006–2006
2 sentences

2006If the majority actually adopted the common law rule, that position would be consistent with the statutory construction rule, cited and centrally relied upon by the majority, that the “common law is changed by statute only if the statute overturns the common law in clear and unambiguous language.” Langle v. Kurkul, 146 Vt. 513, 516 , 510 A.2d 1301, 1303 (1986).

2006If the majority actually adopted the common law rule, that position would be consistent with the statutory construction rule, cited and centrally relied upon by the majority, that the “common law is changed by statute only if the statute overturns the common law in clear and unambiguous language.” Langle v. Kurkul, 146 Vt. 513, 516 , 510 A.2d 1301, 1303 (1986).

44
Aube v. O'BRIENgreen
· 1981 · cited in 1 Vermont opinions naming this issue, 2018–2018
1 sentence

2018There is a longstanding statutory construction principle for statutes of limitation that “where there is a conflict between a general statute of limitations and a specific statute of limitations, the latter will prevail” Aube v. O’Brien, 140 Vt. 1, 4 (1981)(citing Glabach v. Sadelli, 132 Vt. 490, 496 (1974).

11
Vermont Baptist Convention v. Burlington Zoning Boardgreen
vt · 1992 · cited in 1 Vermont opinions naming this issue, 1995–1995
2 sentences

1995See Vermont Baptist Convention, 159 Vt. at 30 , 613 A.2d at 711 .

1995See Vermont Baptist Convention, 159 Vt. at 30 , 613 A.2d at 711 .

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
Glabach v. Sardelli red
vt · 1974
1 sentence

2018There is a longstanding statutory construction principle for statutes of limitation that “where there is a conflict between a general statute of limitations and a specific statute of limitations, the latter will prevail” Aube v. O’Brien, 140 Vt. 1, 4 (1981)(citing Glabach v. Sadelli, 132 Vt. 490, 496 (1974).

12018–2018
St. Paul Fire & Marine Insurance v. Surdam green
vt · 1991
2 sentences

2005Surdam, 156 Vt. at 590 , 595 A.2d at 266 .

2005Surdam, 156 Vt. at 590 , 595 A.2d at 266 .

12005–2005

Statutes the citing opinions construe

VT § Vt. Stat. Ann. tit. 13, § 3201 (4) VT § Vt. Stat. Ann. tit. 13, § 3252 (4) VT § Vt. Stat. Ann. tit. 13, § 3253 (4)

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

FL 81 (1974–2024) PA 68 (1980–2026) TX 52 (1961–2025) CA 41 (1959–2024) MI 34 (1984–2026) IL 30 (1984–2025) WA 28 (1994–2021) OR 24 (1916–2026) MD 22 (1993–2025) NM 11 (1991–2024) TN 10 (1981–2020) WI 10 (1989–2020) CT 9 (1978–2020) OH 8 (1992–2026) VT 7 (1995–2018) LA 7 (1980–2021) GA 6 (2014–2025) IA 6 (1957–2017) CO 6 (1992–2013) WV 5 (1983–2026) VA 5 (2010–2025) NC 5 (1985–2020) AZ 5 (1987–2014) AK 4 (1984–2022) NY 4 (1987–2010) SC 4 (2001–2020) ID 4 (1990–2014) AR 3 (1994–2018) HI 3 (2008–2022) WY 3 (2006–2019) NJ 3 (1984–2016) AL 3 (1952–2001) SD 2 (2001–2001) KS 2 (2007–2013) RI 2 (1996–2011) MO 2 (1994–2024)

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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