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

Vt. Stat. Ann. tit. 09, § 4462 (2026)

Abandonment; unclaimed property

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Subchapter 002 : RESIDENTIAL RENTAL AGREEMENTS

(Cite as: 9 V.S.A. § 4462)
Notes of Decisions
Cited in 7 cases (2 in the last 5 years), 1993–2025 · leading case: JW, LLC v. Ayer & Martell, 2014 VT 71, 101 A.3d 906.
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JW, LLC v. Ayer & Martell, 2014 VT 71, 101 A.3d 906. · cites it 13× “If § 4854a were to confer ownership of any property remaining on the premises 15 days after service of the writ, it would effectively repeal 9 V.S.A. § 4462 which deals with unclaimed property “except trash, garbage or refuse” remaining in a dwelling unit “no longer occupied as…”
Soon K. Kwon v. Eric Edson, 2019 VT 59, 210 VT 557. “See 9 V.S.A. § 4462(a). The court also concluded that tenant Edson was entitled to judgment on landlord’s claims for unpaid rent and electric bills because he moved out in November 2016, before the time when the court found that rent was due from tenants.”
Sawyer v. Robson, 181 Vt. 216 (2006). “Specifically, tenant asserts that even if landlords presented evidence that she no longer occupied that mobile home as a full-time residence and that her rent payments were not current, landlords did not provide adequate support for the third element of the abandonment defense:…”
State v. Roberts, 631 A.2d 835 (Vt. 1993). “* Under 9 V.S.A. § 4462(a) a tenant has abandoned a dwelling unit if: (1) there are circumstances which would lead a reasonable person to believe that the dwelling unit is no longer occupied as a full-time residence; (2) rent is not current; and (3) the landlord has made…”
Sawyer v. Robson, 2006 VT 136, 915 A.2d 1298. “Specifically, tenant asserts that even if landlords presented evidence that she no longer occupied that mobile home as a full-time residence and that her rent payments were not current, landlords did not provide adequate support for the third element of the abandonment defense:…”
Ruest v. Dickson, No. 24-sc-693 (Vt. Super. Ct. Sept. 23, 2024). · cites it 2× “Dickson’s initial position is that Ruest was a tenant and had abandoned her property, which allowed Dickson to dispose of the items under 9 V.S.A. § 4462. The problem with this position is that Ruest was never a tenant as that term is defined in 9 V.”
Execusuite v. Cable, No. 23-cv-2816 (Vt. Super. Ct. Mar. 6, 2025). “9 V.S.A. § 4462. As a general matter, § 4462(a) is an abandonment statute, and it is one of three ways in which the right of possession can be transferred between landlords and tenants.”
Vt. Stat. Ann. tit. 09, § 4462(a): 5 cases
JW, LLC v. Ayer & Martell, 2014 VT 71, 101 A.3d 906. “If § 4854a were to confer ownership of any property remaining on the premises 15 days after service of the writ, it would effectively repeal 9 V.S.A. § 4462 which deals with unclaimed property “except trash, garbage or refuse” remaining in a dwelling unit “no longer occupied as…”
Soon K. Kwon v. Eric Edson, 2019 VT 59, 210 VT 557. “See 9 V.S.A. § 4462(a). The court also concluded that tenant Edson was entitled to judgment on landlord’s claims for unpaid rent and electric bills because he moved out in November 2016, before the time when the court found that rent was due from tenants.”
Sawyer v. Robson, 181 Vt. 216 (2006). “Specifically, tenant asserts that even if landlords presented evidence that she no longer occupied that mobile home as a full-time residence and that her rent payments were not current, landlords did not provide adequate support for the third element of the abandonment defense:…”
State v. Roberts, 631 A.2d 835 (Vt. 1993). “* Under 9 V.S.A. § 4462(a) a tenant has abandoned a dwelling unit if: (1) there are circumstances which would lead a reasonable person to believe that the dwelling unit is no longer occupied as a full-time residence; (2) rent is not current; and (3) the landlord has made…”
Sawyer v. Robson, 2006 VT 136, 915 A.2d 1298. “Specifically, tenant asserts that even if landlords presented evidence that she no longer occupied that mobile home as a full-time residence and that her rent payments were not current, landlords did not provide adequate support for the third element of the abandonment defense:…”
Vt. Stat. Ann. tit. 09, § 4462(c): 1 case
JW, LLC v. Ayer & Martell, 2014 VT 71, 101 A.3d 906. “If § 4854a were to confer ownership of any property remaining on the premises 15 days after service of the writ, it would effectively repeal 9 V.S.A. § 4462 which deals with unclaimed property “except trash, garbage or refuse” remaining in a dwelling unit “no longer occupied as…”
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