Vermont Statutes Annotated

Vt. Stat. Ann. tit. 10, § 8010 (2026)

✓ current as of May 2026
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Subchapter 003 : ENFORCEMENT

(Cite as: 10 V.S.A. § 8010)
Notes of Decisions
Cited in 91 cases (20 in the last 5 years), 1991–2026 · leading case: Agency of Nat. Resources v. Deso, 2003 VT 36 (Vt. 2003).
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Agency of Nat. Resources v. Deso, 2003 VT 36 (Vt. 2003). · cites it 11× “Deso’s first contention is that the court erred by determining that his so-called “wrongful profits” — $161,264 earned from the sale of gasoline without an approved emission control system — was an economic benefit gained from the violation.”
Agency of Nat. Resources v. Godnick, 652 A.2d 988 (Vt. 1994). · cites it 6× “It decided not to impose any penalty under 10 V.SA. § 8010 for violations which occurred before the statute took effect, and for the approximately eleven-month period after November 2, 1990, when the Secretary failed to pursue the violation, concluding this delay in enforcement…”
Sec'y, Vermont Agency of Nat. Resources v. Handy Fam. Enter., 660 A.2d 309 (Vt. 1995). · cites it 4× “The ELD found that the banners were visible from Routes 2 and 2A, and marginally visible from Interstate 89. The ELD also found that other area businesses had been using temporary banners during the time HFE's banners were displayed.”
Sec'y, Vermont Agency of Nat. Resources v. Earth Constr., Inc., 676 A.2d 769 (Vt. 1996). · cites it 3× “They argue that the ELD did not calculate accurately the economic benefits gained from any infraction or, in the alternative, did not give sufficient weight to the violators’ alleged lack of knowledge of the violation.”
State v. Irving Oil Corp., 2008 VT 42 (Vt. 2008). · cites it 2× “These include, to be sure, several criteria concerning the defendant’s culpability, such as whether it “knew or had reason to know the violation existed” and its “record of compliance,” 10 V.S.A. § 8010(b)(3), (4), but on the whole, the factors reflect a primary legislative…”
Vermont Agency of Nat. Resources v. Bean, 672 A.2d 469 (Vt. 1995). · cites it 5× “§ 8012(b), the ELD may review and determine anew the amount of any penalties assessed for violations of Act 250 by applying the criteria set forth in 10 V.S.A. § 8010(b). The criteria to be evaluated include the degree of actual or potential impact on public health, safety,…”
Town of Pawlet v. Daniel Banyai, 2022 VT 4 (Vt. 2022). “10 V.S.A. § 8010(b). ¶ 31. We determine that the Environmental Division did not abuse its discretion when it fined landowner $46,600 for the violations in NOV2.”
Town of Washington v. Emmons, 925 A.2d 1002 (Vt. 2007). “The imposition of financial penalties as part of an administrative order is provided for by 10 V.S.A. § 8010. That section also provides that “imposition of an *589 administrative penalty under this section precludes imposition of any other administrative or civil penalty under…”
Sec'y, Agency of Nat. Resources v. Upper Valley Reg'l Landfill Corp., 705 A.2d 1001 (Vt. 1997). “10 V.S.A. § 8010 (providing explicitly for administrative penalties in administrative orders issued under §§ 8008 or 8009(a), (c)).”
State of Vermont Agency of Nat. Resources v. Riendeau, 603 A.2d 360 (Vt. 1991). “The section that contains the factors to be used in assessing penalties, 10 V.S.A. § 8010, did not become effective until the Secretary of Natural Resources adopted certain rules, 10 V.”
Agency of Nat. Resources v. Francis Supeno, Barbara Supeno, & Barbara Ernst, 185 A.3d 1264 (Vt. 2018). · cites it 3× “10 V.S.A. § 8010(a) (allowing assessment of administrative penalty in context of administrative order or emergency administrative order); see Lamb v.”
ANR v. Vorsteveld Farm, LLP - Decision on Motions (Vt. Super. Ct. 2021). · cites it 13× “5) In response to written discovery propounded by CLF, Zapata Courage, District Wetlands Ecologist, Wetlands Program, and Christopher Gianfagna, Manager, Concentrated Animal Feeding Operation Program, both stated “We determined the $21,750 penalty in the settlement agreement by…”
Show all 91 citing cases →
— Vt. Stat. Ann. tit. 10, § 8010(a) — 1 case
Agency of Nat. Resources v. Francis Supeno, Barbara Supeno, & Barbara Ernst, 185 A.3d 1264 (Vt. 2018). “10 V.S.A. § 8010(a) (allowing assessment of administrative penalty in context of administrative order or emergency administrative order); see Lamb v.”
— Vt. Stat. Ann. tit. 10, § 8010(b) — 56 cases
Town of Pawlet v. Daniel Banyai, 2022 VT 4 (Vt. 2022). “10 V.S.A. § 8010(b). ¶ 31. We determine that the Environmental Division did not abuse its discretion when it fined landowner $46,600 for the violations in NOV2.”
Agency of Nat. Resources v. Godnick, 652 A.2d 988 (Vt. 1994). “It decided not to impose any penalty under 10 V.SA. § 8010 for violations which occurred before the statute took effect, and for the approximately eleven-month period after November 2, 1990, when the Secretary failed to pursue the violation, concluding this delay in enforcement…”
Sec'y, Vermont Agency of Nat. Resources v. Earth Constr., Inc., 676 A.2d 769 (Vt. 1996). “They argue that the ELD did not calculate accurately the economic benefits gained from any infraction or, in the alternative, did not give sufficient weight to the violators’ alleged lack of knowledge of the violation.”
Vermont Agency of Nat. Resources v. Bean, 672 A.2d 469 (Vt. 1995). “§ 8012(b), the ELD may review and determine anew the amount of any penalties assessed for violations of Act 250 by applying the criteria set forth in 10 V.S.A. § 8010(b). The criteria to be evaluated include the degree of actual or potential impact on public health, safety,…”
Agency of Nat. Resources v. Francis Supeno, Barbara Supeno, & Barbara Ernst, 185 A.3d 1264 (Vt. 2018). “10 V.S.A. § 8010(a) (allowing assessment of administrative penalty in context of administrative order or emergency administrative order); see Lamb v.”
— Vt. Stat. Ann. tit. 10, § 8010(b)(1) — 31 cases
Sec'y, Vermont Agency of Nat. Resources v. Handy Fam. Enter., 660 A.2d 309 (Vt. 1995). “The ELD found that the banners were visible from Routes 2 and 2A, and marginally visible from Interstate 89. The ELD also found that other area businesses had been using temporary banners during the time HFE's banners were displayed.”
Vermont Agency of Nat. Resources v. Bean, 672 A.2d 469 (Vt. 1995). “§ 8012(b), the ELD may review and determine anew the amount of any penalties assessed for violations of Act 250 by applying the criteria set forth in 10 V.S.A. § 8010(b). The criteria to be evaluated include the degree of actual or potential impact on public health, safety,…”
ANR v. Supeno, Supeno & Ernst (Vt. Super. Ct. 2017).
ANR B Wesco, Inc. (Vt. Super. Ct. 2017).
ANR v. Wesco, Inc. (Vt. Super. Ct. 2017).
— Vt. Stat. Ann. tit. 10, § 8010(b)(2) — 18 cases
Agency of Nat. Resources v. Godnick, 652 A.2d 988 (Vt. 1994). “It decided not to impose any penalty under 10 V.SA. § 8010 for violations which occurred before the statute took effect, and for the approximately eleven-month period after November 2, 1990, when the Secretary failed to pursue the violation, concluding this delay in enforcement…”
Vermont Agency of Nat. Resources v. Bean, 672 A.2d 469 (Vt. 1995). “§ 8012(b), the ELD may review and determine anew the amount of any penalties assessed for violations of Act 250 by applying the criteria set forth in 10 V.S.A. § 8010(b). The criteria to be evaluated include the degree of actual or potential impact on public health, safety,…”
Vt. Agency of Nat. Resources v. Bean, 672 A.2d 469 (Vt. 1995).
NRB v. Stratton Corp (Vt. Super. Ct. 2016).
Town of Pawlet v. Banyai - Decision on the Merits (Vt. Super. Ct. 2021).
— Vt. Stat. Ann. tit. 10, § 8010(b)(3) — 10 cases
State v. Irving Oil Corp., 2008 VT 42 (Vt. 2008). “These include, to be sure, several criteria concerning the defendant’s culpability, such as whether it “knew or had reason to know the violation existed” and its “record of compliance,” 10 V.S.A. § 8010(b)(3), (4), but on the whole, the factors reflect a primary legislative…”
Town of Pawlet v. Banyai - Decision on the Merits (Vt. Super. Ct. 2021).
ANR v. Wells - Decision on the Merits (Vt. Super. Ct. 2021).
Town of Westford v. Mathieu (Vt. Super. Ct. 2014).
Town of Fairfax v. Beliveau (Vt. Super. Ct. 2012).
— Vt. Stat. Ann. tit. 10, § 8010(b)(4) — 6 cases
Town of Pawlet v. Banyai - Decision on the Merits (Vt. Super. Ct. 2021).
ANR v. Wells - Decision on the Merits (Vt. Super. Ct. 2021).
Town of Westford v. Mathieu (Vt. Super. Ct. 2014).
ANR v. Bacon d/b/a Bacon Timber Harvesting (Vt. Super. Ct. 2010).
ANR v. Bacon d/b/a Bacon Timber Harvesting (Vt. Super. Ct. 2010).
— Vt. Stat. Ann. tit. 10, § 8010(b)(5) — 11 cases
Agency of Nat. Resources v. Deso, 2003 VT 36 (Vt. 2003). “Deso’s first contention is that the court erred by determining that his so-called “wrongful profits” — $161,264 earned from the sale of gasoline without an approved emission control system — was an economic benefit gained from the violation.”
Agency of Nat. Resources v. Godnick, 652 A.2d 988 (Vt. 1994). “It decided not to impose any penalty under 10 V.SA. § 8010 for violations which occurred before the statute took effect, and for the approximately eleven-month period after November 2, 1990, when the Secretary failed to pursue the violation, concluding this delay in enforcement…”
Lee Nov (Vt. Super. Ct. 2016).
Town of Pawlet v. Banyai - Decision on the Merits (Vt. Super. Ct. 2021).
ANR v. Wells - Decision on the Merits (Vt. Super. Ct. 2021).
— Vt. Stat. Ann. tit. 10, § 8010(b)(6) — 15 cases
Sec'y, Vermont Agency of Nat. Resources v. Handy Fam. Enter., 660 A.2d 309 (Vt. 1995). “The ELD found that the banners were visible from Routes 2 and 2A, and marginally visible from Interstate 89. The ELD also found that other area businesses had been using temporary banners during the time HFE's banners were displayed.”
Agency of Nat. Resources v. Deso, 2003 VT 36 (Vt. 2003). “Deso’s first contention is that the court erred by determining that his so-called “wrongful profits” — $161,264 earned from the sale of gasoline without an approved emission control system — was an economic benefit gained from the violation.”
Vermont Agency of Nat. Resources v. Bean, 672 A.2d 469 (Vt. 1995). “§ 8012(b), the ELD may review and determine anew the amount of any penalties assessed for violations of Act 250 by applying the criteria set forth in 10 V.S.A. § 8010(b). The criteria to be evaluated include the degree of actual or potential impact on public health, safety,…”
Vt. Agency of Nat. Resources v. Bean, 672 A.2d 469 (Vt. 1995).
Town of Pawlet v. Banyai - Decision on the Merits (Vt. Super. Ct. 2021).
— Vt. Stat. Ann. tit. 10, § 8010(b)(7) — 11 cases
Town of Pawlet v. Banyai - Decision on the Merits (Vt. Super. Ct. 2021).
ANR v. Wells - Decision on the Merits (Vt. Super. Ct. 2021).
State v. Monsanto (Vt. Super. Ct. 2024).
Town of Marshfield v. Harris - Decision on Merits (Vt. Super. Ct. 2024).
Town of Westford v. Mathieu (Vt. Super. Ct. 2014).
— Vt. Stat. Ann. tit. 10, § 8010(b)(8) — 7 cases
Town of Pawlet v. Banyai - Decision on the Merits (Vt. Super. Ct. 2021).
ANR v. Wells - Decision on the Merits (Vt. Super. Ct. 2021).
NRB v. Stratton (Vt. Super. Ct. 2015).
Town of Westford v. Mathieu (Vt. Super. Ct. 2014).
ANR v. Bacon d/b/a Bacon Timber Harvesting (Vt. Super. Ct. 2010).
— Vt. Stat. Ann. tit. 10, § 8010(b)(l) — 3 cases
State v. Irving Oil Corp., 2008 VT 42 (Vt. 2008). “These include, to be sure, several criteria concerning the defendant’s culpability, such as whether it “knew or had reason to know the violation existed” and its “record of compliance,” 10 V.S.A. § 8010(b)(3), (4), but on the whole, the factors reflect a primary legislative…”
Sec'y, Vermont Agency of Nat. Resources v. Earth Constr., Inc., 676 A.2d 769 (Vt. 1996). “They argue that the ELD did not calculate accurately the economic benefits gained from any infraction or, in the alternative, did not give sufficient weight to the violators’ alleged lack of knowledge of the violation.”
Agency of Nat. Resources v. Timothy Persons & Trust A of Timothy Persons, 2013 VT 46 (Vt. 2013).
— Vt. Stat. Ann. tit. 10, § 8010(c) — 10 cases
Agency of Nat. Resources v. Deso, 2003 VT 36 (Vt. 2003). “Deso’s first contention is that the court erred by determining that his so-called “wrongful profits” — $161,264 earned from the sale of gasoline without an approved emission control system — was an economic benefit gained from the violation.”
Agency of Nat. Resources v. Godnick, 652 A.2d 988 (Vt. 1994). “It decided not to impose any penalty under 10 V.SA. § 8010 for violations which occurred before the statute took effect, and for the approximately eleven-month period after November 2, 1990, when the Secretary failed to pursue the violation, concluding this delay in enforcement…”
Sec'y, Vermont Agency of Nat. Resources v. Earth Constr., Inc., 676 A.2d 769 (Vt. 1996). “They argue that the ELD did not calculate accurately the economic benefits gained from any infraction or, in the alternative, did not give sufficient weight to the violators’ alleged lack of knowledge of the violation.”
ANR v. Supeno, Supeno & Ernst (Vt. Super. Ct. 2017).
ANR B Wesco, Inc. (Vt. Super. Ct. 2017).
— Vt. Stat. Ann. tit. 10, § 8010(c)(1) — 3 cases
ANR v. Vorsteveld Farm, LLP - Decision on Motions (Vt. Super. Ct. 2021). “5) In response to written discovery propounded by CLF, Zapata Courage, District Wetlands Ecologist, Wetlands Program, and Christopher Gianfagna, Manager, Concentrated Animal Feeding Operation Program, both stated “We determined the $21,750 penalty in the settlement agreement by…”
NRB v. Stratton Corp (Vt. Super. Ct. 2016).
ANR v. Blood dba Three Mountain Lodge Restaurant (Vt. Super. Ct. 2010).
— Vt. Stat. Ann. tit. 10, § 8010(c)(2) — 8 cases
ANR v. Bacon d/b/a Bacon Timber Harvesting (Vt. Super. Ct. 2010).
ANR v. Bacon d/b/a Bacon Timber Harvesting (Vt. Super. Ct. 2010).
NRB v. Stratton Corp. (Vt. Super. Ct. 2016).
ANR v. Vorsteveld Farm, LLP - Decision on Motions (Vt. Super. Ct. 2021). “5) In response to written discovery propounded by CLF, Zapata Courage, District Wetlands Ecologist, Wetlands Program, and Christopher Gianfagna, Manager, Concentrated Animal Feeding Operation Program, both stated “We determined the $21,750 penalty in the settlement agreement by…”
ANR v. Foss & Yaratz (Vt. Super. Ct. 2014).
— Vt. Stat. Ann. tit. 10, § 8010(e) — 6 cases
NRB v. Stratton Corp. (Vt. Super. Ct. 2015).
ANR v. Budzyn (Vt. Super. Ct. 2013).
ANR v. Blood dba Three Mountain Lodge Restaurant (Vt. Super. Ct. 2010).
ANR v. Steven Whitham d/b/a Prospect Mountain (Vt. Super. Ct. 2009).
ANR v. Fern Hill Farm, Ltd. & Stephen Bromley (Vt. Super. Ct. 2006).
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