Vt. Stat. Ann. » Title 10 Chapter 153
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 10, § 6237 (2026)

✓ current as of May 2026
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Subchapter 002 : PERMITS AND RULES

(Cite as: 10 V.S.A. § 6237)
Notes of Decisions
Cited in 12 cases (5 in the last 5 years), 1996–2025 · leading case: Shires Hous., Inc. v. Carolyn S. Brown & William A. Shepard, II, 172 A.3d 1215 (Vt. 2017).
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Shires Hous., Inc. v. Carolyn S. Brown & William A. Shepard, II, 172 A.3d 1215 (Vt. 2017). · cites it 26× “We agree with tenant that 10 V.S.A. § 6237(a) is ambiguous, and that the maxims of statutory construction support tenant’s construction of the statute.”
Russell v. Atkins, 679 A.2d 333 (Vt. 1996). “” 10 V.S.A. § 6237(a). Because they proposed both a condominium conversion and a sale of the park, defendants included notice of their intention to sell the park pursuant to 10 V.”
United Park Ass'n v. Ringuette, 719 A.2d 884 (Vt. 1998). · cites it 2× “See 10 VS.A. § 6237(a). Paul Pepin signed the new lease in May 1994 and began making the $100 monthly payments without showing Ringuette his 1992 lease.”
Betty Atkins d/b/a Westbury Park v. Erin Witham & Robert Witham (Vt. 2016). · cites it 2× “” See 10 V.S.A. § 6237(a) (providing that “[a] leaseholder may be evicted only for nonpayment of rent or for a substantial violation of the lease terms of the mobile home park”).”
Mark Bean v. Herbert Bickford (Vt. 2012). · cites it 2× “§ 31, and the court found that landlord did fulfill the statutory requirements for that claim, 10 V.S.A. § 6237(a). The record supports the trial court’s conclusion that the statutory notice requirements were satisfied and that landlord had presented evidence as to the amount of…”
Corse v. Picket (Vt. Super. Ct. 2016). “10 V.S.A. § 6237(a). Its failure to include similar language in Section 4467 is proof that it did not intend to impose that requirement for tenancies in general.”
vt state Hous. v. palowski (Vt. Super. Ct. 2024). “In the case of evictions from mobile-home parks, the prescribed method for delivery of the notice is by certified or registered mail, 10 V.S.A. § 6237(a)(2), but the statute makes no provisions for what should be done when the certified or registered mail is returned as…”
fournier v. wood (Vt. Super. Ct. 2024). “§ 6201 (defining “mobile home park” to mean a parcel where two or more lots are rented for mobile home use and occupancy) and 10 V.S.A. § 6237 (applying to evictions of leaseholders in mobile home parks).”
Addison Cnty. Cmty. Trust v. Streeter (Vt. Super. Ct. 2024). “1 10 V.S.A. § 6237 provides for a specific procedure for eviction of a “leaseholder” in a mobile home park.”
Morrissey v. Wood (Vt. Super. Ct. 2025). “§ 6201 (defining “mobile home park” to mean a parcel where two or more lots are rented for mobile home use and occupancy) and 10 V.S.A. § 6237 (applying to evictions of leaseholders in mobile home parks).”
Addison Cty Comm Trust v. Leduc (Vt. Super. Ct. 2025). “Deppman Filed Date: August 27, 2025 This is an eviction action pursuant to 10 V.S.A. § 6237, brought by Plaintiff Addison County Community Trust, Inc.”
Timothy Miller v. Mortimer Kaufman, Mary Ann Bovat, & Clyde Bovat (Vt. 2013). “In his complaint, plaintiff asserted that defendants had violated 10 V.S.A. § 6237, which provides, in part, that “[a] leaseholder shall not be evicted by force or any other self-help measure,” and 10 V.”
— Vt. Stat. Ann. tit. 10, § 6237(a) — 6 cases
Shires Hous., Inc. v. Carolyn S. Brown & William A. Shepard, II, 172 A.3d 1215 (Vt. 2017). “We agree with tenant that 10 V.S.A. § 6237(a) is ambiguous, and that the maxims of statutory construction support tenant’s construction of the statute.”
Russell v. Atkins, 679 A.2d 333 (Vt. 1996). “” 10 V.S.A. § 6237(a). Because they proposed both a condominium conversion and a sale of the park, defendants included notice of their intention to sell the park pursuant to 10 V.”
United Park Ass'n v. Ringuette, 719 A.2d 884 (Vt. 1998). “See 10 VS.A. § 6237(a). Paul Pepin signed the new lease in May 1994 and began making the $100 monthly payments without showing Ringuette his 1992 lease.”
Betty Atkins d/b/a Westbury Park v. Erin Witham & Robert Witham (Vt. 2016). “” See 10 V.S.A. § 6237(a) (providing that “[a] leaseholder may be evicted only for nonpayment of rent or for a substantial violation of the lease terms of the mobile home park”).”
Corse v. Picket (Vt. Super. Ct. 2016). “10 V.S.A. § 6237(a). Its failure to include similar language in Section 4467 is proof that it did not intend to impose that requirement for tenancies in general.”
— Vt. Stat. Ann. tit. 10, § 6237(a)(2) — 2 cases
Shires Hous., Inc. v. Carolyn S. Brown & William A. Shepard, II, 172 A.3d 1215 (Vt. 2017). “We agree with tenant that 10 V.S.A. § 6237(a) is ambiguous, and that the maxims of statutory construction support tenant’s construction of the statute.”
vt state Hous. v. palowski (Vt. Super. Ct. 2024). “In the case of evictions from mobile-home parks, the prescribed method for delivery of the notice is by certified or registered mail, 10 V.S.A. § 6237(a)(2), but the statute makes no provisions for what should be done when the certified or registered mail is returned as…”
— Vt. Stat. Ann. tit. 10, § 6237(a)(2)(A) — 1 case
Mark Bean v. Herbert Bickford (Vt. 2012). “§ 31, and the court found that landlord did fulfill the statutory requirements for that claim, 10 V.S.A. § 6237(a). The record supports the trial court’s conclusion that the statutory notice requirements were satisfied and that landlord had presented evidence as to the amount of…”
— Vt. Stat. Ann. tit. 10, § 6237(a)(3) — 1 case
Shires Hous., Inc. v. Carolyn S. Brown & William A. Shepard, II, 172 A.3d 1215 (Vt. 2017). “We agree with tenant that 10 V.S.A. § 6237(a) is ambiguous, and that the maxims of statutory construction support tenant’s construction of the statute.”
— Vt. Stat. Ann. tit. 10, § 6237(a)(4) — 1 case
Shires Hous., Inc. v. Carolyn S. Brown & William A. Shepard, II, 172 A.3d 1215 (Vt. 2017). “We agree with tenant that 10 V.S.A. § 6237(a) is ambiguous, and that the maxims of statutory construction support tenant’s construction of the statute.”
— Vt. Stat. Ann. tit. 10, § 6237(a)(5) — 1 case
United Park Ass'n v. Ringuette, 719 A.2d 884 (Vt. 1998). “See 10 VS.A. § 6237(a). Paul Pepin signed the new lease in May 1994 and began making the $100 monthly payments without showing Ringuette his 1992 lease.”
— Vt. Stat. Ann. tit. 10, § 6237(b) — 1 case
Betty Atkins d/b/a Westbury Park v. Erin Witham & Robert Witham (Vt. 2016). “” See 10 V.S.A. § 6237(a) (providing that “[a] leaseholder may be evicted only for nonpayment of rent or for a substantial violation of the lease terms of the mobile home park”).”
— Vt. Stat. Ann. tit. 10, § 6237(e) — 1 case
Shires Hous., Inc. v. Carolyn S. Brown & William A. Shepard, II, 172 A.3d 1215 (Vt. 2017). “We agree with tenant that 10 V.S.A. § 6237(a) is ambiguous, and that the maxims of statutory construction support tenant’s construction of the statute.”
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