Vt. Stat. Ann. » Title 09 Chapter 137
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 4456 (2026)

✓ current as of May 2026
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Subchapter 002 : RESIDENTIAL RENTAL AGREEMENTS

(Cite as: 9 V.S.A. § 4456)
Notes of Decisions
Cited in 8 cases (1 in the last 5 years), 2003–2025 · leading case: Villeneuve v. Beane, 2007 VT 75 (Vt. 2007).
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Villeneuve v. Beane, 2007 VT 75 (Vt. 2007). “The first is that the trial court improperly denied landlord attorney's fees, contending that he was entitled to them not only by a contractual provision in the lease, but also by virtue of 9 V.S.A. § 4456(e), which mandates attorney's fees if the tenants damage the premises.”
Timothy Terry & Penny Terry v. William O'Brien & Susan Cain O'Brien, 2015 VT 132 (Vt. 2015). “Regarding landlords’ appeal of the trial court’s refusal to award them attorney’s fees, landlords’ only argument before the trial court and here on appeal is that they are entitled to attorney’s fees under 9 V.S.A. § 4456(e) because tenants violated § 4456(a) by “contribut[ing]…”
Villeneuve v. Beane, 933 A.2d 1139 (Vt. 2007). “The first is that the trial court improperly denied landlord attorney’s fees, contending that he was entitled to them not only by a contractual provision in the lease, but also by virtue of 9 V.S.A. § 4456(e), which mandates attorney’s fees if the tenants damage the premises.”
E & E Props., Inc. v. Tatro (Vt. Super. Ct. 2012). · cites it 3× “Chapter 127 in that you have repeatedly contributed to the non compliance of the dwelling unit with applicable provisions of building, housing and health regulations in violation of Title 9 V.S.A. Section 4456(a). You are advised to vacate the premises on or before 30 days from…”
Holl v. Ballard (Vt. Super. Ct. 2003). · cites it 2× “The tenant’s responsibility is set forth in the Residential Rental Agreements Act, 9 V.S.A. § 4456(c), which states: The tenant shall not deliberately or negligently destroy, deface, damage or remove any part of the premises or its fixtures, mechanical systems or furnishings or…”
Alden v. Richardson (Vt. Super. Ct. 2017). “In any event, fees were available pursuant to 9 V.S.A. § 4456(e) and the court expressly said that they were awarded because Ms.”
Thorp v. Moonstone (Vt. Super. Ct. 2025). “Attorney’s Fees Plaintiffs are entitled to their attorney’s fees under both 9 V.S.A. § 4456 and 12 V.S.A. § 4854, which allow for attorney’s fees.”
Chagnon v. Peterson (Vt. Super. Ct. 2014). “Chagnon during oral argument require resolution on remand, based on the evidence considered at that time.”
— Vt. Stat. Ann. tit. 09, § 4456(a) — 1 case
E & E Props., Inc. v. Tatro (Vt. Super. Ct. 2012). “Chapter 127 in that you have repeatedly contributed to the non compliance of the dwelling unit with applicable provisions of building, housing and health regulations in violation of Title 9 V.S.A. Section 4456(a). You are advised to vacate the premises on or before 30 days from…”
— Vt. Stat. Ann. tit. 09, § 4456(c) — 1 case
Holl v. Ballard (Vt. Super. Ct. 2003). “The tenant’s responsibility is set forth in the Residential Rental Agreements Act, 9 V.S.A. § 4456(c), which states: The tenant shall not deliberately or negligently destroy, deface, damage or remove any part of the premises or its fixtures, mechanical systems or furnishings or…”
— Vt. Stat. Ann. tit. 09, § 4456(d) — 2 cases
Chagnon v. Peterson (Vt. Super. Ct. 2014). “Chagnon during oral argument require resolution on remand, based on the evidence considered at that time.”
Holl v. Ballard (Vt. Super. Ct. 2003). “The tenant’s responsibility is set forth in the Residential Rental Agreements Act, 9 V.S.A. § 4456(c), which states: The tenant shall not deliberately or negligently destroy, deface, damage or remove any part of the premises or its fixtures, mechanical systems or furnishings or…”
— Vt. Stat. Ann. tit. 09, § 4456(e) — 5 cases
Villeneuve v. Beane, 2007 VT 75 (Vt. 2007). “The first is that the trial court improperly denied landlord attorney's fees, contending that he was entitled to them not only by a contractual provision in the lease, but also by virtue of 9 V.S.A. § 4456(e), which mandates attorney's fees if the tenants damage the premises.”
Timothy Terry & Penny Terry v. William O'Brien & Susan Cain O'Brien, 2015 VT 132 (Vt. 2015). “Regarding landlords’ appeal of the trial court’s refusal to award them attorney’s fees, landlords’ only argument before the trial court and here on appeal is that they are entitled to attorney’s fees under 9 V.S.A. § 4456(e) because tenants violated § 4456(a) by “contribut[ing]…”
Villeneuve v. Beane, 933 A.2d 1139 (Vt. 2007). “The first is that the trial court improperly denied landlord attorney’s fees, contending that he was entitled to them not only by a contractual provision in the lease, but also by virtue of 9 V.S.A. § 4456(e), which mandates attorney’s fees if the tenants damage the premises.”
Alden v. Richardson (Vt. Super. Ct. 2017). “In any event, fees were available pursuant to 9 V.S.A. § 4456(e) and the court expressly said that they were awarded because Ms.”
E & E Props., Inc. v. Tatro (Vt. Super. Ct. 2012). “Chapter 127 in that you have repeatedly contributed to the non compliance of the dwelling unit with applicable provisions of building, housing and health regulations in violation of Title 9 V.S.A. Section 4456(a). You are advised to vacate the premises on or before 30 days from…”
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