Vermont Statutes Annotated

Vt. Stat. Ann. tit. 08, § 4203 (2026)

✓ current as of May 2026
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Subchapter 001 : POLICIES

(Cite as: 8 V.S.A. § 4203)
Notes of Decisions
Cited in 22 cases (1 in the last 5 years), 1974–2025 · leading case: Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009).
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Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009). · cites it 2× “See 8 V.S.A. § 4203(5), (6) ("[p]olicies of motor vehicle insurance"); id.”
Blake v. Nationwide Ins., 2006 VT 48 (Vt. 2006). “The superior court ruled that plaintiff could bring this direct action against Nationwide to establish coverage if he fit within 8 V.S.A. § 4203(3). That section provides that if the insured is insolvent or bankrupt, the injured party may bring a direct action against the…”
Guiel v. Allstate Ins., 756 A.2d 777 (Vt. 2000). · cites it 3× “See 8 V.S.A. § 4203(4). These arguments are not persuasive.”
T. Copeland & Sons, Inc. v. Kansa Gen. Ins., 762 A.2d 471 (Vt. 2000). · cites it 5× “While “loss” traditionally has been defined as the amount of an insured’s financial detriment that the insurer becomes liable to pay, we believe that the Legislature broadened “loss” to include the financial detriment suffered by a third party.”
Korda v. Chicago Ins. Co., 2006 VT 81 (Vt. 2006). · cites it 7× “We also conclude that the subrogation action was filed within the limitations period of 8 V.S.A. § 4203(2), assuming the allegations of the complaint are proved.”
Coop. Fire Ins. Ass'n v. Bizon, 693 A.2d 722 (Vt. 1997). · cites it 2× “We also note that Cooperative Fire made defendant a party, initially so that it could seek a restraining order against defendant’s prosecution of the wrongful death suit, but thereafter defendant participated as the only party opposing plaintiff’s claim. Further, we note that…”
In Re Ambassador Ins. Co., Inc., 2008 VT 105 (Vt. 2008). “See 8 V.S.A. § 4203(3) (allowing injured persons to maintain a direct action against an insurance company if the insured becomes insolvent or bankrupt).”
State v. Glens Falls Ins., 404 A.2d 101 (Vt. 1979). “8 V.S.A. § 4203 (emphasis added). We find in this statute a legislative declaration of a public policy favoring complete coverage.”
R.L. Vallee, Inc. v. Am. Int'l Specialty Lines Ins., 431 F. Supp. 2d 428 (D. Vt. 2006). “” Vt. Stat. Ann. tit. 8 § 4203(3). Hence, when the insured is insolvent or bankrupt, the injured party may bring suit against the insurer “under the terms of the policy, for the amount of any judgment obtained against the insured not exceeding the limits of the policy.”
Bennett Est. v. Travelers Ins., 438 A.2d 380 (Vt. 1981). · cites it 2× “A formal judgment order incorporating the findings was filed on January 30, 1974.”
Bennett Est. v. Travelers Ins. Co., 413 A.2d 1208 (Vt. 1980). “See 8 V.S.A. § 4203(3). At a hearing in chambers on the later action, the superior court, acting sua sponte, objected to the 1974 judgment on the ground that it was based on findings and conclusions signed by the presiding judge, but not by either assistant judge.”
Norfolk & Dedham Fire Ins. v. Aetna Cas. & Sur. Co., 318 A.2d 659 (Vt. 1974). “8 V.S.A. § 4203(4). Subrogation arises when one man is compelled to pay a debt for which another is primarily liable and which, in good conscience, should have been discharged by the latter.”
Show all 22 citing cases →
— Vt. Stat. Ann. tit. 08, § 4203(1) — 1 case
T. Copeland & Sons, Inc. v. Kansa Gen. Ins., 762 A.2d 471 (Vt. 2000). “While “loss” traditionally has been defined as the amount of an insured’s financial detriment that the insurer becomes liable to pay, we believe that the Legislature broadened “loss” to include the financial detriment suffered by a third party.”
— Vt. Stat. Ann. tit. 08, § 4203(2) — 3 cases
Korda v. Chicago Ins. Co., 2006 VT 81 (Vt. 2006). “We also conclude that the subrogation action was filed within the limitations period of 8 V.S.A. § 4203(2), assuming the allegations of the complaint are proved.”
T. Copeland & Sons, Inc. v. Kansa Gen. Ins., 762 A.2d 471 (Vt. 2000). “While “loss” traditionally has been defined as the amount of an insured’s financial detriment that the insurer becomes liable to pay, we believe that the Legislature broadened “loss” to include the financial detriment suffered by a third party.”
Shahi v. The Stand. Fire Ins. Co., 523 F. App'x 38 (2d Cir. 2013).
— Vt. Stat. Ann. tit. 08, § 4203(3) — 10 cases
Blake v. Nationwide Ins., 2006 VT 48 (Vt. 2006). “The superior court ruled that plaintiff could bring this direct action against Nationwide to establish coverage if he fit within 8 V.S.A. § 4203(3). That section provides that if the insured is insolvent or bankrupt, the injured party may bring a direct action against the…”
Coop. Fire Ins. Ass'n v. Bizon, 693 A.2d 722 (Vt. 1997). “We also note that Cooperative Fire made defendant a party, initially so that it could seek a restraining order against defendant’s prosecution of the wrongful death suit, but thereafter defendant participated as the only party opposing plaintiff’s claim. Further, we note that…”
In Re Ambassador Ins. Co., Inc., 2008 VT 105 (Vt. 2008). “See 8 V.S.A. § 4203(3) (allowing injured persons to maintain a direct action against an insurance company if the insured becomes insolvent or bankrupt).”
R.L. Vallee, Inc. v. Am. Int'l Specialty Lines Ins., 431 F. Supp. 2d 428 (D. Vt. 2006). “” Vt. Stat. Ann. tit. 8 § 4203(3). Hence, when the insured is insolvent or bankrupt, the injured party may bring suit against the insurer “under the terms of the policy, for the amount of any judgment obtained against the insured not exceeding the limits of the policy.”
Bennett Est. v. Travelers Ins., 438 A.2d 380 (Vt. 1981). “A formal judgment order incorporating the findings was filed on January 30, 1974.”
— Vt. Stat. Ann. tit. 08, § 4203(4) — 8 cases
Guiel v. Allstate Ins., 756 A.2d 777 (Vt. 2000). “See 8 V.S.A. § 4203(4). These arguments are not persuasive.”
Norfolk & Dedham Fire Ins. v. Aetna Cas. & Sur. Co., 318 A.2d 659 (Vt. 1974). “8 V.S.A. § 4203(4). Subrogation arises when one man is compelled to pay a debt for which another is primarily liable and which, in good conscience, should have been discharged by the latter.”
Lopez v. Concord Gen. Mut. Ins. Grp., 583 A.2d 602 (Vt. 1990).
Jefferson Ins. v. Travelers Ins., 614 A.2d 385 (Vt. 1992).
Klimek v. Horace Mann Ins., 817 F. Supp. 430 (D. Vt. 1993).
— Vt. Stat. Ann. tit. 08, § 4203(5) — 1 case
Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009). “See 8 V.S.A. § 4203(5), (6) ("[p]olicies of motor vehicle insurance"); id.”
— Vt. Stat. Ann. tit. 08, § 4203(l) — 1 case
T. Copeland & Sons, Inc. v. Kansa Gen. Ins., 762 A.2d 471 (Vt. 2000). “While “loss” traditionally has been defined as the amount of an insured’s financial detriment that the insurer becomes liable to pay, we believe that the Legislature broadened “loss” to include the financial detriment suffered by a third party.”
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