Vt. Stat. Ann. » Title 09 Chapter 63
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 2451 (2026)

✓ current as of May 2026
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Subchapter 001 : GENERAL PROVISIONS

(Cite as: 9 V.S.A. § 2451)
Notes of Decisions
Cited in 82 cases (16 in the last 5 years), 1973–2026 · leading case: In re Pharm. Indus. Average Wholesale Price Litig., 252 F.R.D. 83 (D. Mass. 2008).
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In re Pharm. Indus. Average Wholesale Price Litig., 252 F.R.D. 83 (D. Mass. 2008). · cites it 4× “), Vermont ( Vt. Stat. Ann. tit. 9, § 2451 , et seq.) and Washington (Wash.”
Patane v. Nestlé Waters N. Am., Inc., 369 F. Supp. 3d 382 (D. Conn. 2019). · cites it 2× “# 160 at 28, 305-306 (citing VT. STAT. ANN. tit. 9, § 2451, et seq. ; tit.”
Gramatan Home Investors Corp. v. Starling, 470 A.2d 1157 (Vt. 1983). · cites it 2× “§§ 1601-1635 , and Vermont’s Consumer Fraud Act, 9 V.S.A. § 2451. Under 15 U.S.C. § 1635 an obligor in a consumer credit transaction, in which a security interest is acquired on the obligor’s principal dwelling place, has three days to rescind the credit transaction following…”
Elkins v. Microsoft Corp., 817 A.2d 9 (Vt. 2002). “The plain meaning of the language is supported by the express legislative intent behind the statute to “protect the public” against “unfair or deceptive acts or practices” and to “encourage fair and honest competition.”
EBWS, LLC v. Britly Corp., 2007 VT 37 (Vt. 2007). “See generally Consumer Fraud Act, 9 V.S.A. § 2451. To survive summary judgment, EBWS must demonstrate: (1) that Britly made a representation or omission that was likely to mislead; (2) that EBWS interpreted the message reasonably under the circumstances; and (3) that the…”
Meadowbrook Condo. Ass'n v. South Burlington Realty Corp., 565 A.2d 238 (Vt. 1989). · cites it 2× “Second, defendant argues that, irrespective of the Act's applicability, the punitive damages award was improper because the court did not find that the requisite "actual malice" had been established.”
State v. Custom Pools, 556 A.2d 72 (Vt. 1988). · cites it 2× “This appeal, brought by the State of Vermont, requires us to determine the authority of the Attorney General to proceed under the Consumer Fraud Act, 9 V.S.A. § 2451 et seq., against the holders of notes and mortgages obtained by their assignor in violation of the Act.”
GEICO Corp. v. Autoliv, Inc., 345 F. Supp. 3d 799 (E.D. Mich. 2018). “Under the Vermont Consumer Fraud Act ("VCFA"), Vt. Stat. Ann. tit. 9, § 2451 et seq. , only a "consumer" may bring a suit alleging a violation of this statute, Vt.”
Sawyer v. Robson, 181 Vt. 216 (Vt. 2006). · cites it 2× “The plain meaning of "other violator" is anyone engaged in an unfair or deceptive commercial practice in violation of the CFA's prohibition on such activity. Stated another way, our focus in determining applicability of the CFA is the nature of the alleged violator's activities,…”
State of Vermont v. Mphj Tech. Investments, 803 F.3d 635 (Fed. Cir. 2015). “On May 8, 2013, Plaintiff-Appellee State of Vermont (“Vermont” or “the State”) filed a state court action against Defendant-Appellant MPHJ Technology Investments LLC (“MPHJ”) alleging violations of the Vermont Consumer Protection Act, 9 V.S.A. §§ 2451 et seq. (“VCPA”). The…”
Gov't of the United States Virgin Islands v. Takata Corp., 67 V.I. 316 (2017). “2d 9 (2002) (discussing 9 V.S.A. § 2451 et seep). Sec 12A V.I.C. § 302.”
Carter v. Gugliuzzi, 716 A.2d 17 (Vt. 1998). “Smith Bell first contends the court erred in ruling that the Consumer Fraud Act applied to the deceptive acts of real estate *52 brokers against home buyers.”
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— Vt. Stat. Ann. tit. 09, § 2451(a) — 1 case
State v. Big Bro. SEC. Programs (Vt. Super. Ct. 2020).
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