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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 10, § 6615 (2026)

✓ current as of May 2026
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Subchapter 001 : GENERAL PROVISIONS

(Cite as: 10 V.S.A. § 6615)
Notes of Decisions
Cited in 31 cases (10 in the last 5 years), 1993–2025 · leading case: State v. Howe Cleaners, Inc., 2010 VT 70 (Vt. 2010).
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State v. Howe Cleaners, Inc., 2010 VT 70 (Vt. 2010). · cites it 19× “In January 2004, the State brought an action in the superior court pursuant to 10 V.S.A. § 6615 of Vermont's Waste Management Act (VWMA) and the common law of public nuisance against the current owner, Fiore, and various past owners and operators of the site, including Banknorth…”
State of Vermont Agency of Nat. Resources v. Parkway Cleaners, 210 A.3d 445 (Vt. 2019). · cites it 9× “Additionally, the court found that "[defendant] ha[d] not assumed his legal responsibility under 10 V.S.A. § 6615, and show[ed] no signs of doing so.”
Windsor Sch. Dist. v. State, 2008 VT 27 (Vt. 2008). · cites it 6× “” 10 V.S.A. § 6615®. 5 The original consultant’s and attorney’s fees awards were reduced by an amount equal to the small payments received from the Vermont Department of Education.”
Hardwick Recycling & Salvage, Inc. v. Acadia Ins., 2004 VT 124 (Vt. 2004). · cites it 3× “Johnson Controls, 2003 WI108, ¶ 120. In the absence of a specific exclusion, a -reasonable insured, reading the “as damages” language and assessing the coverage he is about to buy, would conclude that the policy provides indemnification for costs incurred by complying with a…”
Town of Milton Bd. of Health v. Armand Brisson, 2016 VT 56 (Vt. 2016). · cites it 2× “Such an implication should be avoided, particularly where many of these statutes have remedial purposes intended to protect the public health and environment. ¶ 54.”
The Est. of Richard S. Daniels, by & through Julie Lyford in her capacity as, 2022 VT 2 (Vt. 2022). · cites it 15× “In July 2010, the state filed a complaint against plaintiff, individually and as principal of Hazen Street, under 10 V.S.A. §§ 6615 and 8221, asserting he was liable for the hazardous-waste contamination as the current owner of the property.”
State v. Carroll, 765 A.2d 500 (Vt. 2000). · cites it 5× “In August 1997, the State of Vermont brought an action against the Carrolls under 10 V.S.A. § 6615 for clean-up costs it had incurred in its ongoing efforts to remedy petroleum contamination located on a piece of property owned by the Carrolls.”
Folino v. Hampden Color & Chem. Co., 832 F. Supp. 757 (D. Vt. 1993). · cites it 5× “, as amended (“CERCLA”); 2) defendant’s claims under the Vermont Waste Management Act, 10 V.S.A. § 6615 (‘VWMA”); and 3) plaintiffs’ claim for attorney’s fees pursuant to a lease agreement between the parties.”
State v. Irving Oil Corp., 2008 VT 42 (Vt. 2008). · cites it 2× “We hold, in conclusion, that neither the State’s prayer for recovery of response costs under 10 V.S.A. § 6615, nor its request for civil penalties pursuant to 10 V.”
Knappmiller v. Bove, 2012 VT 38 (Vt. 2012). · cites it 2× “The trial court concluded that both the town and the DOC were strictly liable as responsible parties under 10 V.S.A. § 6615(a), a provision of the Vermont Waste Management Act, and therefore both were liable for cleanup.”
Bradford Oil Co. v. Stonington Ins. Co. v. State of Vermont Agency of Nat. Resources, 2011 VT 108 (Vt. 2011). “Because the station owner is subject to joint and several liability under 10 V.S.A. § 6615(c), and faced the risk of a hazardous waste migration, the State argues that the owner expects that the policy would impose the same joint and *338 several liability on the insurer.”
State v. Carroll, 2003 VT 57 (Vt. 2003). “In August 1997, the State filed a claim against defendants, under 10 V.S.A. § 6615, seeking to recover the costs already incurred and those expected to be incurred “to clean up a petroleum release on property owned by defendants.”
Show all 31 citing cases →
— Vt. Stat. Ann. tit. 10, § 6615(a) — 12 cases
Windsor Sch. Dist. v. State, 2008 VT 27 (Vt. 2008). “” 10 V.S.A. § 6615®. 5 The original consultant’s and attorney’s fees awards were reduced by an amount equal to the small payments received from the Vermont Department of Education.”
State of Vermont Agency of Nat. Resources v. Parkway Cleaners, 210 A.3d 445 (Vt. 2019). “Additionally, the court found that "[defendant] ha[d] not assumed his legal responsibility under 10 V.S.A. § 6615, and show[ed] no signs of doing so.”
State v. Irving Oil Corp., 2008 VT 42 (Vt. 2008). “We hold, in conclusion, that neither the State’s prayer for recovery of response costs under 10 V.S.A. § 6615, nor its request for civil penalties pursuant to 10 V.”
Folino v. Hampden Color & Chem. Co., 832 F. Supp. 757 (D. Vt. 1993). “, as amended (“CERCLA”); 2) defendant’s claims under the Vermont Waste Management Act, 10 V.S.A. § 6615 (‘VWMA”); and 3) plaintiffs’ claim for attorney’s fees pursuant to a lease agreement between the parties.”
Knappmiller v. Bove, 2012 VT 38 (Vt. 2012). “The trial court concluded that both the town and the DOC were strictly liable as responsible parties under 10 V.S.A. § 6615(a), a provision of the Vermont Waste Management Act, and therefore both were liable for cleanup.”
— Vt. Stat. Ann. tit. 10, § 6615(a)(1) — 5 cases
State of Vermont Agency of Nat. Resources v. Parkway Cleaners, 210 A.3d 445 (Vt. 2019). “Additionally, the court found that "[defendant] ha[d] not assumed his legal responsibility under 10 V.S.A. § 6615, and show[ed] no signs of doing so.”
The Est. of Richard S. Daniels, by & through Julie Lyford in her capacity as, 2022 VT 2 (Vt. 2022). “In July 2010, the state filed a complaint against plaintiff, individually and as principal of Hazen Street, under 10 V.S.A. §§ 6615 and 8221, asserting he was liable for the hazardous-waste contamination as the current owner of the property.”
Agency of Nat. Resources v. Parkway Cleaners (Vt. Super. Ct. 2014).
state v. bradford oil (Vt. Super. Ct. 2023).
State of Vermont v. Bradford Oil Co., Inc. (Vt. Super. Ct. 2012).
— Vt. Stat. Ann. tit. 10, § 6615(a)(2) — 3 cases
State v. Howe Cleaners, Inc., 2010 VT 70 (Vt. 2010). “In January 2004, the State brought an action in the superior court pursuant to 10 V.S.A. § 6615 of Vermont's Waste Management Act (VWMA) and the common law of public nuisance against the current owner, Fiore, and various past owners and operators of the site, including Banknorth…”
state v. bradford oil (Vt. Super. Ct. 2023).
state v. bradford oil (Vt. Super. Ct. 2023).
— Vt. Stat. Ann. tit. 10, § 6615(a)(3) — 1 case
state v. bradford oil (Vt. Super. Ct. 2023).
— Vt. Stat. Ann. tit. 10, § 6615(a)(4)(A) — 1 case
State v. Howe Cleaners, Inc., 2010 VT 70 (Vt. 2010). “In January 2004, the State brought an action in the superior court pursuant to 10 V.S.A. § 6615 of Vermont's Waste Management Act (VWMA) and the common law of public nuisance against the current owner, Fiore, and various past owners and operators of the site, including Banknorth…”
— Vt. Stat. Ann. tit. 10, § 6615(a)(4)(B) — 3 cases
Windsor Sch. Dist. v. State, 2008 VT 27 (Vt. 2008). “” 10 V.S.A. § 6615®. 5 The original consultant’s and attorney’s fees awards were reduced by an amount equal to the small payments received from the Vermont Department of Education.”
Folino v. Hampden Color & Chem. Co., 832 F. Supp. 757 (D. Vt. 1993). “, as amended (“CERCLA”); 2) defendant’s claims under the Vermont Waste Management Act, 10 V.S.A. § 6615 (‘VWMA”); and 3) plaintiffs’ claim for attorney’s fees pursuant to a lease agreement between the parties.”
Bradford Oil CAP (Vt. Super. Ct. 2014).
— Vt. Stat. Ann. tit. 10, § 6615(a)(5) — 4 cases
State v. Monsanto (Vt. Super. Ct. 2024).
Neddo (D. Vt. 2025).
Addison Cent. Sch. Dist. v. Monsanto Co. (D. Vt. 2024).
Addison Cent. Sch. Dist. v. Monsanto Co. (D. Vt. 2024).
— Vt. Stat. Ann. tit. 10, § 6615(a)(l) — 1 case
Hardwick Recycling & Salvage, Inc. v. Acadia Ins., 2004 VT 124 (Vt. 2004). “Johnson Controls, 2003 WI108, ¶ 120. In the absence of a specific exclusion, a -reasonable insured, reading the “as damages” language and assessing the coverage he is about to buy, would conclude that the policy provides indemnification for costs incurred by complying with a…”
— Vt. Stat. Ann. tit. 10, § 6615(b) — 1 case
The Est. of Richard S. Daniels, by & through Julie Lyford in her capacity as, 2022 VT 2 (Vt. 2022). “In July 2010, the state filed a complaint against plaintiff, individually and as principal of Hazen Street, under 10 V.S.A. §§ 6615 and 8221, asserting he was liable for the hazardous-waste contamination as the current owner of the property.”
— Vt. Stat. Ann. tit. 10, § 6615(c) — 7 cases
Bradford Oil Co. v. Stonington Ins. Co. v. State of Vermont Agency of Nat. Resources, 2011 VT 108 (Vt. 2011). “Because the station owner is subject to joint and several liability under 10 V.S.A. § 6615(c), and faced the risk of a hazardous waste migration, the State argues that the owner expects that the policy would impose the same joint and *338 several liability on the insurer.”
State v. Carroll, 765 A.2d 500 (Vt. 2000). “In August 1997, the State of Vermont brought an action against the Carrolls under 10 V.S.A. § 6615 for clean-up costs it had incurred in its ongoing efforts to remedy petroleum contamination located on a piece of property owned by the Carrolls.”
Knappmiller v. Bove, 2012 VT 38 (Vt. 2012). “The trial court concluded that both the town and the DOC were strictly liable as responsible parties under 10 V.S.A. § 6615(a), a provision of the Vermont Waste Management Act, and therefore both were liable for cleanup.”
The Est. of Richard S. Daniels, by & through Julie Lyford in her capacity as, 2022 VT 2 (Vt. 2022). “In July 2010, the state filed a complaint against plaintiff, individually and as principal of Hazen Street, under 10 V.S.A. §§ 6615 and 8221, asserting he was liable for the hazardous-waste contamination as the current owner of the property.”
state v. bradford oil (Vt. Super. Ct. 2023).
— Vt. Stat. Ann. tit. 10, § 6615(d) — 2 cases
State v. Howe Cleaners, Inc., 2010 VT 70 (Vt. 2010). “In January 2004, the State brought an action in the superior court pursuant to 10 V.S.A. § 6615 of Vermont's Waste Management Act (VWMA) and the common law of public nuisance against the current owner, Fiore, and various past owners and operators of the site, including Banknorth…”
state v. bradford oil (Vt. Super. Ct. 2023).
— Vt. Stat. Ann. tit. 10, § 6615(d)(1) — 2 cases
state v. bradford oil (Vt. Super. Ct. 2023).
State of Vermont v. Bradford Oil Co., Inc. (Vt. Super. Ct. 2012).
— Vt. Stat. Ann. tit. 10, § 6615(d)(1)(A) — 2 cases
state v. bradford oil (Vt. Super. Ct. 2023).
State of Vermont v. Bradford Oil Co., Inc. (Vt. Super. Ct. 2012).
— Vt. Stat. Ann. tit. 10, § 6615(d)(1)(C) — 2 cases
State of Vermont v. Bradford Oil Co., Inc. (Vt. Super. Ct. 2012).
state v. bradford oil (Vt. Super. Ct. 2023).
— Vt. Stat. Ann. tit. 10, § 6615(e) — 7 cases
State v. Howe Cleaners, Inc., 2010 VT 70 (Vt. 2010). “In January 2004, the State brought an action in the superior court pursuant to 10 V.S.A. § 6615 of Vermont's Waste Management Act (VWMA) and the common law of public nuisance against the current owner, Fiore, and various past owners and operators of the site, including Banknorth…”
State of Vermont Agency of Nat. Resources v. Parkway Cleaners, 210 A.3d 445 (Vt. 2019). “Additionally, the court found that "[defendant] ha[d] not assumed his legal responsibility under 10 V.S.A. § 6615, and show[ed] no signs of doing so.”
The Est. of Richard S. Daniels, by & through Julie Lyford in her capacity as, 2022 VT 2 (Vt. 2022). “In July 2010, the state filed a complaint against plaintiff, individually and as principal of Hazen Street, under 10 V.S.A. §§ 6615 and 8221, asserting he was liable for the hazardous-waste contamination as the current owner of the property.”
state v. bradford oil (Vt. Super. Ct. 2023).
State of Vermont v. Bradford Oil Co., Inc. (Vt. Super. Ct. 2012).
— Vt. Stat. Ann. tit. 10, § 6615(g)(1)(A) — 1 case
Pownal Dev. Corp. v. Pownal Tanning Co., 765 A.2d 489 (Vt. 2000).
— Vt. Stat. Ann. tit. 10, § 6615(h) — 1 case
Pownal Dev. Corp. v. Pownal Tanning Co., 765 A.2d 489 (Vt. 2000).
— Vt. Stat. Ann. tit. 10, § 6615(i) — 6 cases
Town of Milton Bd. of Health v. Armand Brisson, 2016 VT 56 (Vt. 2016). “Such an implication should be avoided, particularly where many of these statutes have remedial purposes intended to protect the public health and environment. ¶ 54.”
Windsor Sch. Dist. v. State, 2008 VT 27 (Vt. 2008). “” 10 V.S.A. § 6615®. 5 The original consultant’s and attorney’s fees awards were reduced by an amount equal to the small payments received from the Vermont Department of Education.”
State v. Carroll, 765 A.2d 500 (Vt. 2000). “In August 1997, the State of Vermont brought an action against the Carrolls under 10 V.S.A. § 6615 for clean-up costs it had incurred in its ongoing efforts to remedy petroleum contamination located on a piece of property owned by the Carrolls.”
The Est. of Richard S. Daniels, by & through Julie Lyford in her capacity as, 2022 VT 2 (Vt. 2022). “In July 2010, the state filed a complaint against plaintiff, individually and as principal of Hazen Street, under 10 V.S.A. §§ 6615 and 8221, asserting he was liable for the hazardous-waste contamination as the current owner of the property.”
state v. bradford oil (Vt. Super. Ct. 2023).
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