Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 4465 (2026)

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

(Cite as: 9 V.S.A. § 4465)
Notes of Decisions
Cited in 11 cases (4 in the last 5 years), 1988–2026 · leading case: Houle v. Quenneville, 787 A.2d 1258 (Vt. 2001).
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Houle v. Quenneville, 787 A.2d 1258 (Vt. 2001). · cites it 16× “Applicability of the retaliatory eviction defense The prohibition against retaliatory conduct is set out in 9 V.S.A. § 4465, which provides as follows: (a) A landlord of a residential dwelling unit may not retaliate by establishing or changing terms of a rental agreement or by…”
Gokey v. Bessette, 580 A.2d 488 (Vt. 1990). · cites it 4× “In addition, the court awarded defendants $300 for the loss of the freezer food, $800 for the “discomfort and distress for the lockout of the barn for the months June to October, 1986,” $1,600 for the retaliatory eviction under 9 V.S.A. § 4465, 1 and $700 in attorney’s fees, for…”
Imperial Colliery Co. v. Fout, 373 S.E.2d 489 (W. Va. 1988). “057; Vt. Stat.Ann. tit. 9, § 4465; Wis.Stat.Ann.”
Espenschied v. Mallick, 633 A.2d 388 (D.C. 1993). “§ 47-8-39; N.Y.Real Prop.Law § 223-b; N.C.Gen.”
Stacy v. Douglas (Vt. Super. Ct. 2025). · cites it 2× “Burns and Austin cite to the rebuttable presumption of retaliation under 9 V.S.A. § 4465. The Defendants’ second defense is that their middle child has been recently diagnosed with autism and is currently enrolled in a good program in the Williamstown school district.”
Stephens v. Gilmour (Vt. Super. Ct. 2025). · cites it 2× “3) Retaliatory Eviction under 9 V.S.A. § 4465 based on the following alleged facts: a.”
Atwood v. Hill (Vt. Super. Ct. 2024). “engaging in retaliatory action, specifically: A landlord of a residential dwelling unit may not retaliate by establishing or changing terms of a rental agreement or by bringing or threatening to bring an action against a tenant who: (1) has complained to a governmental agency…”
Seventy Four South Main v. Dunbar (Vt. Super. Ct. 2026). “There is no evidence that Plaintiff was on notice of any defects or unrepaired issues that would give rise to a right to withhold under either 9 V.”
Martin Webster v. Steve Anderson (Vt. 2012). “560 (1990)] that the retaliatory eviction statute, 9 V.S.A. § 4465(a)(2), did not contemplate use of a subjective test for evaluating what is retaliatory conduct.”
Vladyka v. Marsh (Vt. Super. Ct. 2010). “9 V.S.A. § 4465(a). If the landlord does retaliate, the tenant is entitled to recover damages and reasonable attorney’s fees and has a defense in any retaliatory action for possession.”
Northgate Hous. Ltd. v. White (Vt. Super. Ct. 2004). “The Whites have counterclaimed that the eviction was retaliatory, in violation of 9 V.S.A. § 4465, and that Northgate Housing has violated their federal rights.”
— Vt. Stat. Ann. tit. 09, § 4465(a) — 5 cases
Houle v. Quenneville, 787 A.2d 1258 (Vt. 2001). “Applicability of the retaliatory eviction defense The prohibition against retaliatory conduct is set out in 9 V.S.A. § 4465, which provides as follows: (a) A landlord of a residential dwelling unit may not retaliate by establishing or changing terms of a rental agreement or by…”
Gokey v. Bessette, 580 A.2d 488 (Vt. 1990). “In addition, the court awarded defendants $300 for the loss of the freezer food, $800 for the “discomfort and distress for the lockout of the barn for the months June to October, 1986,” $1,600 for the retaliatory eviction under 9 V.S.A. § 4465, 1 and $700 in attorney’s fees, for…”
Atwood v. Hill (Vt. Super. Ct. 2024). “engaging in retaliatory action, specifically: A landlord of a residential dwelling unit may not retaliate by establishing or changing terms of a rental agreement or by bringing or threatening to bring an action against a tenant who: (1) has complained to a governmental agency…”
Stephens v. Gilmour (Vt. Super. Ct. 2025). “3) Retaliatory Eviction under 9 V.S.A. § 4465 based on the following alleged facts: a.”
Vladyka v. Marsh (Vt. Super. Ct. 2010). “9 V.S.A. § 4465(a). If the landlord does retaliate, the tenant is entitled to recover damages and reasonable attorney’s fees and has a defense in any retaliatory action for possession.”
— Vt. Stat. Ann. tit. 09, § 4465(a)(1)(3) — 1 case
Houle v. Quenneville, 787 A.2d 1258 (Vt. 2001). “Applicability of the retaliatory eviction defense The prohibition against retaliatory conduct is set out in 9 V.S.A. § 4465, which provides as follows: (a) A landlord of a residential dwelling unit may not retaliate by establishing or changing terms of a rental agreement or by…”
— Vt. Stat. Ann. tit. 09, § 4465(a)(2) — 3 cases
Houle v. Quenneville, 787 A.2d 1258 (Vt. 2001). “Applicability of the retaliatory eviction defense The prohibition against retaliatory conduct is set out in 9 V.S.A. § 4465, which provides as follows: (a) A landlord of a residential dwelling unit may not retaliate by establishing or changing terms of a rental agreement or by…”
Gokey v. Bessette, 580 A.2d 488 (Vt. 1990). “In addition, the court awarded defendants $300 for the loss of the freezer food, $800 for the “discomfort and distress for the lockout of the barn for the months June to October, 1986,” $1,600 for the retaliatory eviction under 9 V.S.A. § 4465, 1 and $700 in attorney’s fees, for…”
Martin Webster v. Steve Anderson (Vt. 2012). “560 (1990)] that the retaliatory eviction statute, 9 V.S.A. § 4465(a)(2), did not contemplate use of a subjective test for evaluating what is retaliatory conduct.”
— Vt. Stat. Ann. tit. 09, § 4465(b) — 1 case
Houle v. Quenneville, 787 A.2d 1258 (Vt. 2001). “Applicability of the retaliatory eviction defense The prohibition against retaliatory conduct is set out in 9 V.S.A. § 4465, which provides as follows: (a) A landlord of a residential dwelling unit may not retaliate by establishing or changing terms of a rental agreement or by…”
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