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

Vt. Stat. Ann. tit. 09, § 4461 (2026)

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

(Cite as: 9 V.S.A. § 4461)
Notes of Decisions
Cited in 25 cases (9 in the last 5 years), 1990–2026 · leading case: In Re Soon Kwon, 2011 VT 26 (Vt. 2011).
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In Re Soon Kwon, 2011 VT 26 (Vt. 2011). · cites it 4× “” 9 V.S.A. § 4461(d). The ordinance supplements this requirement with two additional provisions: one requires that tenants “furnish the owner a forwarding address to enable the owner to return all or part of the deposit as required,” and the other provides that landlords “shall…”
State v. Hemingway, 2014 VT 48 (Vt. 2014). · cites it 4× “¶ 17 (quoting 9 V.S.A. § 4461(e)). This Court held that the statute created a bright-line rule and that even if a tenant had actual notice, failure to comply with the notice provision resulted in forfeiture of the deposit.”
Tanneberger v. Paeplow (In Re Paeplow), 217 B.R. 705 (Bankr. D. Vt. 1998). · cites it 6× “The Tannebergers moved out on January 5, 1997 and Vermont law Title 9 V.S.A. § 4461 2 required Paeplow to either return the security deposit or provide a written statement itemizing the reasons for any deductions within 14 days.”
Daniels v. Elks Club of Hartford & the Human Rights Comm'n, 2012 VT 55 (Vt. 2012). · cites it 2× “) (emphasizing that “the landlord shall” language in 9 V.S.A. § 4461(d) meant that “[t]he method of delivery is explicit in the statute”).”
Dennis v. Hall (In re Hall), 483 B.R. 281 (Bankr. D. Conn. 2012). “An analysis of the landlord and tenant statute with respect to security deposits in Vermont, see 9 V.S.A. § 4461, is examined by the court in Tanneberger v.”
Nepveu v. Rau, 583 A.2d 1273 (Vt. 1990). · cites it 2× “See 9 V.S.A. § 4461(b)(1) (“landlord may retain all or a portion of the *376 security deposit for .”
Burdo v. Handys Hotels (Vt. Super. Ct. 2026). · cites it 4× “” 9 V.S.A. § 4461(c), (e). A “willful” failure makes landlord liable for twice the amount “wrongfully withheld, plus reasonable attorney’s fees and costs.”
riley v. dempsey (Vt. Super. Ct. 2023). · cites it 3× “” The Small Claims Court did cite to, and quote from, 9 V.S.A. § 4461, in its discussion of the counterclaim, but there is no specific citation to the statutory definition of “normal wear and tear” which appears in the definitions at 9 .”
Atwood v. Hill (Vt. Super. Ct. 2024). · cites it 3× “A landlord is held to strict compliance with Section 4461 and is explicitly required to “return the security deposit along with a written statement itemizing any deductions to a tenant within 14 days.”
Georges Way v. Harrington (Vt. Super. Ct. 2025). · cites it 3× “” 9 V.S.A. § 4461(c) (emphasis added). This provision applies to all residential leases, regardless of the specific lease language.”
Sousis v. Santana (Vt. Super. Ct. 2026). · cites it 3× “” 9 V.S.A. § 4461. The Vermont Supreme Court has held that the requirements of this statute must be observed in a rigorous manner.”
Sheryl Tepper & Stephen Kesman v. Patricia Garcia (Vt. 2015). · cites it 5× “andlords assert that they provided notice of their intent to withhold the deposit as early as June 16, 2014, when they filed the complaint for writ of possession which contained a sentence stating that “[p]laintiffs reserve the right to bring additional causes of action…”
Show all 25 citing cases →
— Vt. Stat. Ann. tit. 09, § 4461(a) — 3 cases
Tanneberger v. Paeplow (In Re Paeplow), 217 B.R. 705 (Bankr. D. Vt. 1998). “The Tannebergers moved out on January 5, 1997 and Vermont law Title 9 V.S.A. § 4461 2 required Paeplow to either return the security deposit or provide a written statement itemizing the reasons for any deductions within 14 days.”
Mtc Vt v. Warner (Vt. Super. Ct. 2025).
71 Drew v. Burlington Hous. Bd (Vt. Super. Ct. 2025).
— Vt. Stat. Ann. tit. 09, § 4461(b) — 1 case
Kaitlin Barry v. Chris C. Khamnei (Vt. 2013).
— Vt. Stat. Ann. tit. 09, § 4461(b)(1) — 1 case
Nepveu v. Rau, 583 A.2d 1273 (Vt. 1990). “See 9 V.S.A. § 4461(b)(1) (“landlord may retain all or a portion of the *376 security deposit for .”
— Vt. Stat. Ann. tit. 09, § 4461(b)(2) — 2 cases
riley v. dempsey (Vt. Super. Ct. 2023). “” The Small Claims Court did cite to, and quote from, 9 V.S.A. § 4461, in its discussion of the counterclaim, but there is no specific citation to the statutory definition of “normal wear and tear” which appears in the definitions at 9 .”
Riley v. Dempsey (Vt. Super. Ct. 2005).
— Vt. Stat. Ann. tit. 09, § 4461(c) — 7 cases
Tanneberger v. Paeplow (In Re Paeplow), 217 B.R. 705 (Bankr. D. Vt. 1998). “The Tannebergers moved out on January 5, 1997 and Vermont law Title 9 V.S.A. § 4461 2 required Paeplow to either return the security deposit or provide a written statement itemizing the reasons for any deductions within 14 days.”
Atwood v. Hill (Vt. Super. Ct. 2024). “A landlord is held to strict compliance with Section 4461 and is explicitly required to “return the security deposit along with a written statement itemizing any deductions to a tenant within 14 days.”
Georges Way v. Harrington (Vt. Super. Ct. 2025). “” 9 V.S.A. § 4461(c) (emphasis added). This provision applies to all residential leases, regardless of the specific lease language.”
Burdo v. Handys Hotels (Vt. Super. Ct. 2026). “” 9 V.S.A. § 4461(c), (e). A “willful” failure makes landlord liable for twice the amount “wrongfully withheld, plus reasonable attorney’s fees and costs.”
Sousis v. Santana (Vt. Super. Ct. 2026). “” 9 V.S.A. § 4461. The Vermont Supreme Court has held that the requirements of this statute must be observed in a rigorous manner.”
— Vt. Stat. Ann. tit. 09, § 4461(d) — 4 cases
In Re Soon Kwon, 2011 VT 26 (Vt. 2011). “” 9 V.S.A. § 4461(d). The ordinance supplements this requirement with two additional provisions: one requires that tenants “furnish the owner a forwarding address to enable the owner to return all or part of the deposit as required,” and the other provides that landlords “shall…”
State v. Hemingway, 2014 VT 48 (Vt. 2014). “¶ 17 (quoting 9 V.S.A. § 4461(e)). This Court held that the statute created a bright-line rule and that even if a tenant had actual notice, failure to comply with the notice provision resulted in forfeiture of the deposit.”
Daniels v. Elks Club of Hartford & the Human Rights Comm'n, 2012 VT 55 (Vt. 2012). “) (emphasizing that “the landlord shall” language in 9 V.S.A. § 4461(d) meant that “[t]he method of delivery is explicit in the statute”).”
Sousis v. Santana (Vt. Super. Ct. 2026). “” 9 V.S.A. § 4461. The Vermont Supreme Court has held that the requirements of this statute must be observed in a rigorous manner.”
— Vt. Stat. Ann. tit. 09, § 4461(e) — 15 cases
State v. Hemingway, 2014 VT 48 (Vt. 2014). “¶ 17 (quoting 9 V.S.A. § 4461(e)). This Court held that the statute created a bright-line rule and that even if a tenant had actual notice, failure to comply with the notice provision resulted in forfeiture of the deposit.”
In Re Soon Kwon, 2011 VT 26 (Vt. 2011). “” 9 V.S.A. § 4461(d). The ordinance supplements this requirement with two additional provisions: one requires that tenants “furnish the owner a forwarding address to enable the owner to return all or part of the deposit as required,” and the other provides that landlords “shall…”
Burdo v. Handys Hotels (Vt. Super. Ct. 2026). “” 9 V.S.A. § 4461(c), (e). A “willful” failure makes landlord liable for twice the amount “wrongfully withheld, plus reasonable attorney’s fees and costs.”
Eliason v. Harrison (Vt. Super. Ct. 2018).
Georges Way v. Harrington (Vt. Super. Ct. 2025). “” 9 V.S.A. § 4461(c) (emphasis added). This provision applies to all residential leases, regardless of the specific lease language.”
— Vt. Stat. Ann. tit. 09, § 4461(g) — 1 case
In Re Soon Kwon, 2011 VT 26 (Vt. 2011). “” 9 V.S.A. § 4461(d). The ordinance supplements this requirement with two additional provisions: one requires that tenants “furnish the owner a forwarding address to enable the owner to return all or part of the deposit as required,” and the other provides that landlords “shall…”
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