Vt. Stat. Ann. » Title 09 Chapter 137
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Vt. Stat. Ann. tit. 09, § 4451 (2026)

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Subchapter 001 : GENERAL

(Cite as: 9 V.S.A. § 4451)
Notes of Decisions
Cited in 44 cases (30 in the last 5 years), 1999–2026 · leading case: Soon K. Kwon v. Eric Edson, 2019 VT 59, 210 VT 557.
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Soon K. Kwon v. Eric Edson, 2019 VT 59, 210 VT 557. · cites it 2× “Having concluded that there was support in the record for the court’s finding that the parties orally agreed that tenants could live in the apartment rent-free, we conclude that defendants were indeed tenants.”
Houle v. Quenneville, 787 A.2d 1258 (Vt. 2001). · cites it 2× “Accordingly, tenants still qualified as tenants, see 9 V.S.A. § 4451(9) ("`Tenant' means a person entitled under a rental agreement to occupy a residential dwelling unit to the exclusion of others"), and were eligible to assert the retaliatory eviction defense.”
In re Soon Kwon, 2011 VT 26, 19 A.3d 139. “” 9 V.S.A. § 4451(1). Landlord’s argument is based on a definition of actual notice as receipt of written notice, regardless of how that notice is delivered.”
Mongeon Bay Props., LLC v. Mallets Bay Homeowner's Assn., Anthony J. Sineni & Merrimack Mortagage Co., 2016 VT 64, 149 A.3d 940. “2014) (emphasis added); see also 9 V.S.A. § 4451(5) (defining “normal wear and tear” for purposes of residential rental agreements as “the deterioration which occurs, based upon the reasonable use for which the rental unit is intended, without negligence, carelessness, accident,…”
Vermont Tenants, Inc. v. Vermont Hous. Fin. Agency, 742 A.2d 745 (Vt. 1999). · cites it 2× “” 9 V.S.A. § 4451. Since the tenant no longer fits the RRAA definition of “tenant,” RRAA does not apply.”
In re William J. McCarty, Jr., 2013 VT 47, 75 A.3d 589. “See 9 V.S.A. § 4451(8). The landlord must provide adequate notice to terminate a tenancy.”
Downtown Barre Dev. v. GU Markets of Barre, LLC, 2011 VT 45, 22 A.3d 1174. “, 9 V.S.A. § 4451 (defining “actual notice” for residential rental agreements as “receipt of written notice hand-delivered or mailed to the last known address.”
Timothy Terry v. William O'Brien, 2015 VT 132, 134 A.3d 203. “See 9 V.S.A. § 4451(1) (stating that term “Actual notice” as used in chapter “means receipt of written notice hand-delivered or mailed to last known address.”
fournier v. wood, No. 23-cv-4339 (Vt. Super. Ct. Mar. 15, 2024). · cites it 6× “9 V.S.A. § 4451. The Vermont Residential Rental Act applies all “rental agreements,” and its obligations are imposed on “landlords” and “tenants.”
Morrissey v. Wood, No. 24-cv-4467 (Vt. Super. Ct. Feb. 18, 2025). · cites it 4× “First, the Vermont Residential Rental Act (9 V.S.A.§§ 4451–4468a), by definition, applies to rental agreements formed between landlords and tenants for dwelling units as these terms are defined under 9 V.”
Garcia v. Birch, No. 24-cv-1231 (Vt. Super. Ct. Sept. 23, 2024). · cites it 3× “The notices do not cite to a date certain, and they appear to have been taped to the door of the units, which is not a method of delivery allowed under the definition of “actual notice” as that term is defined in 9 V.S.A. § 4451. For these reasons, these initial notices are…”
Atwood v. Hill, No. 24-cv-1091 (Vt. Super. Ct. Oct. 17, 2024). · cites it 3× “Conclusions of Law Plaintiff’s Claims This action is governed by the requirements and terms of Vermont’s Residential Rental Agreements Act, 9 V.S.A. § 4451 et seq. A “landlord may terminate a tenancy for nonpayment of rent by providing actual notice to the tenant of the date on…”
Show all 44 citing cases →
Vt. Stat. Ann. tit. 09, § 4451(1): 16 cases
In re Soon Kwon, 2011 VT 26, 19 A.3d 139. “” 9 V.S.A. § 4451(1). Landlord’s argument is based on a definition of actual notice as receipt of written notice, regardless of how that notice is delivered.”
Timothy Terry v. William O'Brien, 2015 VT 132, 134 A.3d 203. “See 9 V.S.A. § 4451(1) (stating that term “Actual notice” as used in chapter “means receipt of written notice hand-delivered or mailed to last known address.”
bogie v. whitcomb, No. 23-cv-4828 (Vt. Super. Ct. Mar. 15, 2024).
Atwood v. Hill, No. 24-cv-1091 (Vt. Super. Ct. Oct. 17, 2024). “Conclusions of Law Plaintiff’s Claims This action is governed by the requirements and terms of Vermont’s Residential Rental Agreements Act, 9 V.S.A. § 4451 et seq. A “landlord may terminate a tenancy for nonpayment of rent by providing actual notice to the tenant of the date on…”
Schiller v. Lewis, No. 24-cv-3083 (Vt. Super. Ct. Jan. 9, 2025).
Vt. Stat. Ann. tit. 09, § 4451(10): 4 cases
Soon K. Kwon v. Eric Edson, 2019 VT 59, 210 VT 557. “Having concluded that there was support in the record for the court’s finding that the parties orally agreed that tenants could live in the apartment rent-free, we conclude that defendants were indeed tenants.”
fournier v. wood, No. 23-cv-4339 (Vt. Super. Ct. Mar. 15, 2024). “9 V.S.A. § 4451. The Vermont Residential Rental Act applies all “rental agreements,” and its obligations are imposed on “landlords” and “tenants.”
Branchwood Hous. v. Tabor, No. 22-cv-893 (Vt. Super. Ct. Jan. 9, 2025).
Rogers v. Rogers, No. 25-cv-2185 (Vt. Super. Ct. Dec. 15, 2025).
Vt. Stat. Ann. tit. 09, § 4451(2): 1 case
Eliason v. Harrison, No. 745-9-16 Cncv (Vt. Super. Ct. June 26, 2018).
Vt. Stat. Ann. tit. 09, § 4451(3): 2 cases
fournier v. wood, No. 23-cv-4339 (Vt. Super. Ct. Mar. 15, 2024). “9 V.S.A. § 4451. The Vermont Residential Rental Act applies all “rental agreements,” and its obligations are imposed on “landlords” and “tenants.”
Morrissey v. Wood, No. 24-cv-4467 (Vt. Super. Ct. Feb. 18, 2025). “First, the Vermont Residential Rental Act (9 V.S.A.§§ 4451–4468a), by definition, applies to rental agreements formed between landlords and tenants for dwelling units as these terms are defined under 9 V.”
Vt. Stat. Ann. tit. 09, § 4451(4): 2 cases
Vermont Tenants, Inc. v. Vermont Hous. Fin. Agency, 742 A.2d 745 (Vt. 1999). “” 9 V.S.A. § 4451. Since the tenant no longer fits the RRAA definition of “tenant,” RRAA does not apply.”
fournier v. wood, No. 23-cv-4339 (Vt. Super. Ct. Mar. 15, 2024). “9 V.S.A. § 4451. The Vermont Residential Rental Act applies all “rental agreements,” and its obligations are imposed on “landlords” and “tenants.”
Vt. Stat. Ann. tit. 09, § 4451(5): 5 cases
Mongeon Bay Props., LLC v. Mallets Bay Homeowner's Assn., Anthony J. Sineni & Merrimack Mortagage Co., 2016 VT 64, 149 A.3d 940. “2014) (emphasis added); see also 9 V.S.A. § 4451(5) (defining “normal wear and tear” for purposes of residential rental agreements as “the deterioration which occurs, based upon the reasonable use for which the rental unit is intended, without negligence, carelessness, accident,…”
71 Drew v. Burlington Hous. Bd, No. 25-cv-247 (Vt. Super. Ct. Aug. 27, 2025).
Riley v. Dempsey, No. 425 (Vt. Super. Ct. Jan. 5, 2005).
riley v. dempsey, No. 425-8-04 wrcv (Vt. Super. Ct. Nov. 7, 2023).
MTC Vt v. Warner, No. 25-cv-1707 (Vt. Super. Ct. July 22, 2025).
Vt. Stat. Ann. tit. 09, § 4451(7): 1 case
In re Kurt Daims/Brattleboro Common Sense, No. 23-AP-306 (Vt. July 12, 2024).
Vt. Stat. Ann. tit. 09, § 4451(8): 6 cases
Soon K. Kwon v. Eric Edson, 2019 VT 59, 210 VT 557. “Having concluded that there was support in the record for the court’s finding that the parties orally agreed that tenants could live in the apartment rent-free, we conclude that defendants were indeed tenants.”
In re William J. McCarty, Jr., 2013 VT 47, 75 A.3d 589. “See 9 V.S.A. § 4451(8). The landlord must provide adequate notice to terminate a tenancy.”
Pe1 Hous. v. Damon, No. 25-cv-5466 (Vt. Super. Ct. Apr. 16, 2026).
fournier v. wood, No. 23-cv-4339 (Vt. Super. Ct. Mar. 15, 2024). “9 V.S.A. § 4451. The Vermont Residential Rental Act applies all “rental agreements,” and its obligations are imposed on “landlords” and “tenants.”
Deblasio v. Hathaway, No. 25-cv-3007 (Vt. Super. Ct. Feb. 12, 2026).
Vt. Stat. Ann. tit. 09, § 4451(9): 1 case
Houle v. Quenneville, 787 A.2d 1258 (Vt. 2001). “Accordingly, tenants still qualified as tenants, see 9 V.S.A. § 4451(9) ("`Tenant' means a person entitled under a rental agreement to occupy a residential dwelling unit to the exclusion of others"), and were eligible to assert the retaliatory eviction defense.”
Vt. Stat. Ann. tit. 09, § 4451(a): 1 case
Giancola v. Boyd, No. 24-cv-3073 (Vt. Super. Ct. Dec. 16, 2024).
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