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

Vt. Stat. Ann. tit. 09, § 2453 (2026)

✓ current as of May 2026
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Subchapter 001 : GENERAL PROVISIONS

(Cite as: 9 V.S.A. § 2453)
Notes of Decisions
Cited in 176 cases (47 in the last 5 years), 1972–2026 · leading case: Dernier v. Mortg. Network, Inc., 87 A.3d 465 (Vt. 2013).
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Dernier v. Mortg. Network, Inc., 87 A.3d 465 (Vt. 2013). · cites it 4× “§ 2461(b), plaintiffs focus on the first requirement — that the act itself must be either “unfair” or “deceptive” so as to be rendered illegal by 9 V.S.A. § 2453, to which § 2461 refers. “Unfair” acts and “deceptive” acts each have their own tests that we have defined through…”
Elkins v. Microsoft Corp., 817 A.2d 9 (Vt. 2002). · cites it 3× “The central provision of the VCFA is 9 V.S.A. § 2453(a), which provides: (a) Unfair methods of competition in commerce, and unfair or deceptive acts or practices in commerce, are hereby declared unlawful.”
Poulin v. Ford Motor Co., 513 A.2d 1168 (Vt. 1986). · cites it 5× “The complaint alleged violations of express and implied warranties, intentional misrepresentation and violation of the Consumer Fraud Act, 9 V.S.A. § 2453. After trial, the jury awarded the plaintiff $40,000.”
Jordan v. Nissan North Am., Inc., 2004 VT 27 (Vt. 2004). · cites it 2× “on plaintiffs’ claims under Vermont’s Consumer Fraud Act, 9 V.S.A. § 2453(a). Plaintiffs allege that defendants violated the Act by representing a Nissan Quest as an import when the minivan was actually assembled in the United States.”
Bruntaeger v. Zeller, 515 A.2d 123 (Vt. 1986). · cites it 3× “After a bench trial, the court found that the sale was a home solicitation sale, and that defendant’s failure to provide plaintiff with a written notice of her cancellation rights violated 9 V.S.A. § 2453. The court found that plaintiff had rejected nonconforming goods and…”
Bisson v. Ward, 628 A.2d 1256 (Vt. 1993). · cites it 3× “§ 2453]” to bring suit against the violator and recover damages, reasonable attorney’s fees, and “exemplary damages not exceeding three times the value of the consideration given by the consumer.” 9 V.S.A. § 2461(b). “Consumer” is defined by the Act as: any person who purchases,…”
Russell v. Atkins, 679 A.2d 333 (Vt. 1996). · cites it 4× “amended by the Federal Trade Commission and the courts of the United States.”
State v. Int'l Collection Serv., Inc., 594 A.2d 426 (Vt. 1991). · cites it 4× “First, the basic prohibition of the Act is contained in 9 V.S.A. § 2453(a), which provides that “[ujnfair methods of competition in commerce, and unfair or deceptive acts or practices in commerce, are hereby declared unlawful.”
People Ex Rel. Harris v. Pac Anchor Transp., Inc., 329 P.3d 180 (Cal. 2014). “§ 56:8-2 [prohibiting fraud and deceptive trade practices]; Vt. Stat. Ann. tit. 9, § 2453 [prohibiting unfair trade practices in commerce]; Wis.”
Peabody v. P.J.'s Auto Vill., Inc., 569 A.2d 460 (Vt. 1989). · cites it 3× “She lost her *56 suit for damages under Vermont’s Consumer Fraud Act, 9 V.S.A. § 2453(a), resulting from P.J.’s sale to her of the front of a 1974 Saab welded to the back of a 1972 Saab, known-in the trade as a “clipped” vehicle.”
State v. Custom Pools, 556 A.2d 72 (Vt. 1988). · cites it 3× “At trial, Custom defaulted, and the trial court sitting without a jury found that the mortgage transactions of Custom were unfair and deceptive business transactions. Accordingly, judgment was entered against Custom.”
Wilder v. Aetna Life & Cas. Ins., 433 A.2d 309 (Vt. 1981). · cites it 2× “00 set-off against the settlement amount, because it mistakenly paid plaintiffs’ guardian that amount in addition to the $20,000 settlement reached with the guardian for her own injuries. Plaintiffs alleged that the refusal to pay was an unfair insurance practice, 8 V.”
Show all 176 citing cases →
— Vt. Stat. Ann. tit. 09, § 2453(a) — 107 cases
Jordan v. Nissan North Am., Inc., 2004 VT 27 (Vt. 2004). “on plaintiffs’ claims under Vermont’s Consumer Fraud Act, 9 V.S.A. § 2453(a). Plaintiffs allege that defendants violated the Act by representing a Nissan Quest as an import when the minivan was actually assembled in the United States.”
Bruntaeger v. Zeller, 515 A.2d 123 (Vt. 1986). “After a bench trial, the court found that the sale was a home solicitation sale, and that defendant’s failure to provide plaintiff with a written notice of her cancellation rights violated 9 V.S.A. § 2453. The court found that plaintiff had rejected nonconforming goods and…”
In re Generic Pharm. Pricing Antitrust Litig., 368 F. Supp. 3d 814 (E.D. Pa. 2019).
Elkins v. Microsoft Corp., 817 A.2d 9 (Vt. 2002). “The central provision of the VCFA is 9 V.S.A. § 2453(a), which provides: (a) Unfair methods of competition in commerce, and unfair or deceptive acts or practices in commerce, are hereby declared unlawful.”
Poulin v. Ford Motor Co., 513 A.2d 1168 (Vt. 1986). “The complaint alleged violations of express and implied warranties, intentional misrepresentation and violation of the Consumer Fraud Act, 9 V.S.A. § 2453. After trial, the jury awarded the plaintiff $40,000.”
— Vt. Stat. Ann. tit. 09, § 2453(b) — 23 cases
State v. Howe Cleaners, Inc., 2010 VT 70 (Vt. 2010).
Elkins v. Microsoft Corp., 817 A.2d 9 (Vt. 2002). “The central provision of the VCFA is 9 V.S.A. § 2453(a), which provides: (a) Unfair methods of competition in commerce, and unfair or deceptive acts or practices in commerce, are hereby declared unlawful.”
In re Relafen Antitrust Litig., 221 F.R.D. 260 (D. Mass. 2004).
State v. Int'l Collection Serv., Inc., 594 A.2d 426 (Vt. 1991). “First, the basic prohibition of the Act is contained in 9 V.S.A. § 2453(a), which provides that “[ujnfair methods of competition in commerce, and unfair or deceptive acts or practices in commerce, are hereby declared unlawful.”
Carter v. Gugliuzzi, 716 A.2d 17 (Vt. 1998).
— Vt. Stat. Ann. tit. 09, § 2453(c) — 5 cases
Elkins v. Microsoft Corp., 817 A.2d 9 (Vt. 2002). “The central provision of the VCFA is 9 V.S.A. § 2453(a), which provides: (a) Unfair methods of competition in commerce, and unfair or deceptive acts or practices in commerce, are hereby declared unlawful.”
Hershenson v. Lake Champlain Motors, Inc., 424 A.2d 1075 (Vt. 1981).
Giancola v. Boyd (Vt. Super. Ct. 2024).
Mears v. Avm Builder Supply (Vt. Super. Ct. 2026).
Banknorth, N.A. v. Littlefield (Vt. Super. Ct. 2005).
— Vt. Stat. Ann. tit. 09, § 2453(d) — 3 cases
Turner v. Baxley, 354 F. Supp. 963 (D. Vt. 1972).
Giancola v. Boyd (Vt. Super. Ct. 2024).
Mears v. Avm Builder Supply (Vt. Super. Ct. 2026).
— Vt. Stat. Ann. tit. 09, § 2453(e) — 4 cases
PH West Dover Prop., LLC. v. Lalancette Engineers, 2015 VT 48 (Vt. 2015).
Turner v. Baxley, 354 F. Supp. 963 (D. Vt. 1972).
PH West Dover Prop., LLC., Frankenberg & Fredreck v. Lalancette Engineers, Lalancette & Barbara Walowit Realty, Inc., 199 Vt. 1 (Vt. 2015).
Edstrom v. Marshall (Vt. Super. Ct. 2024).
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