Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 512 (2026)

✓ current as of May 2026
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Subchapter 002 : ACTIONS LIMITED

(Cite as: 12 V.S.A. § 512)
Notes of Decisions
Cited in 123 cases (31 in the last 5 years), 1963–2026 · leading case: Cavanaugh v. Abbott Labs., 496 A.2d 154 (Vt. 1985).
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Cavanaugh v. Abbott Labs., 496 A.2d 154 (Vt. 1985). · cites it 17× “678 (1931), as an outmoded and unrealistic interpretation of the term “accrues” as used in 12 V.S.A. § 512 (personal injury action must be commenced within three years “after the cause of action accrues” and not after), and hold that plaintiff’s cause of action is not barred by…”
Stewart v. Darrow, 448 A.2d 788 (Vt. 1982). · cites it 37× “The issue both below and on appeal is which of the three limitation statutes controlled the claim: the original 12 V.”
Fitzgerald v. Congleton, 583 A.2d 595 (Vt. 1990). · cites it 6× “2d 677 (1976), which discussed the concept in more detail and observed that “since at least 1915, the applicability of [12 V.S.A. § 512] has been predicated upon the nature of the harm for which recovery is sought and not upon the nature of the action brought.”
Linda Morse v. Univ. of Vermont, 973 F.2d 122 (2d Cir. 1992). · cites it 3× “Accordingly, Judge Parker properly applied Vermont’s three-year statute of limitations for personal injury actions, Vt.Stat.Ann. tit. 12, § 512(4), to Morse’s § 504 Rehabilitation Act suit and correctly granted summary judgment dismissing it as time-barred.”
Capron v. Romeyn, 409 A.2d 565 (Vt. 1979). · cites it 10× “Allen, supra, particularly compelling in view of the fact that the legislature has now, in effect, by the amendment to 12 V.S.A. § 512 (4), overruled that case.”
A.B. v. S.U., 2023 VT 32 (Vt. 2023). · cites it 3× “12 V.S.A. § 512. Under 1 V.S.A. § 214(b)(1), legislative enactments generally do not “affect the operation of the act or provision prior to the effective date of the amendment.”
Inv. Props., Inc. v. Lyttle, 739 A.2d 1222 (Vt. 1999). · cites it 4× “See 12 V.S.A. § 512. Plaintiffs argue that this Court should look to the underlying harm — the damage to the condominiums — in determining the applicable statute of limitations.”
Shields v. Gerhart, 582 A.2d 153 (Vt. 1990). · cites it 5× “Defendants answered the complaint and filed their motion to dismiss on three grounds: (1) plaintiff’s Civil Rights Act claims are time-barred because they were not brought within the three year period allowed by 12 V.S.A. § 512(4); (2) her claims under *145 the Vermont…”
Bull v. Pinkham Eng'g Assocs., Inc., 752 A.2d 26 (Vt. 2000). · cites it 2× “Statute of Limitations Defendant first contends that plaintiffs’ claim for lost profits is barred by 12 V.S.A. § 512(5), which provides that an action for damage to personal property caused by the act or default of another must be commenced within three years after the cause of…”
Politi v. Tyler, 751 A.2d 788 (Vt. 2000). · cites it 4× “2d 595 (1990), in which we held that claims resulting in "mental anguish, emotional distress, and personal humiliation" were covered under 12 V.S.A. § 512(4)'s three-year statute of limitations, id.”
South Burlington Sch. Dist. v. Goodrich, 382 A.2d 220 (Vt. 1977). · cites it 4× “12 V.S.A. § 512(4). The majority acknowledges that the modern trend of the law is towards the adoption of the discovery rule, and their view is amply supported by well-reasoned authority in the decisional law of sister states.”
Morse v. Univ. of Vermont, 776 F. Supp. 844 (D. Vt. 1991). · cites it 7× “The Vermont person injury statute of limitations, 12 V.S.A. § 512 states in pertinent part: Actions for the following causes shall be commenced within three years after the cause of action accrues, and not after: (4) Except as otherwise provided in this chapter, injuries to the…”
Show all 123 citing cases →
— Vt. Stat. Ann. tit. 12, § 512(1) — 2 cases
Barquin v. Roman Catholic Diocese, 839 F. Supp. 275 (D. Vt. 1993).
Dasler v. Knapp (D. Vt. 2021).
— Vt. Stat. Ann. tit. 12, § 512(2) — 1 case
Dasler v. Knapp (D. Vt. 2021).
— Vt. Stat. Ann. tit. 12, § 512(3) — 9 cases
Dulude v. Fletcher Allen Health Care, Inc., 807 A.2d 390 (Vt. 2002).
Harold Noel Arrowsmith, Jr. v. United Press Int'l, 320 F.2d 219 (2d Cir. 1963).
Sulaiman J. Jadallah v. Town of Fairfax, Stacy Wells, Gabriel Handy & Sidon Pantry, LLC, 186 A.3d 1111 (Vt. 2018).
MacIa v. Microsoft Corp., 152 F. Supp. 2d 535 (D. Vt. 2001).
Allco Renewable Energy Ltd. v. Kulkin (D. Vt. 2020).
— Vt. Stat. Ann. tit. 12, § 512(4) — 62 cases
Stewart v. Darrow, 448 A.2d 788 (Vt. 1982). “The issue both below and on appeal is which of the three limitation statutes controlled the claim: the original 12 V.”
Cavanaugh v. Abbott Labs., 496 A.2d 154 (Vt. 1985). “678 (1931), as an outmoded and unrealistic interpretation of the term “accrues” as used in 12 V.S.A. § 512 (personal injury action must be commenced within three years “after the cause of action accrues” and not after), and hold that plaintiff’s cause of action is not barred by…”
Linda Morse v. Univ. of Vermont, 973 F.2d 122 (2d Cir. 1992). “Accordingly, Judge Parker properly applied Vermont’s three-year statute of limitations for personal injury actions, Vt.Stat.Ann. tit. 12, § 512(4), to Morse’s § 504 Rehabilitation Act suit and correctly granted summary judgment dismissing it as time-barred.”
Fitzgerald v. Congleton, 583 A.2d 595 (Vt. 1990). “2d 677 (1976), which discussed the concept in more detail and observed that “since at least 1915, the applicability of [12 V.S.A. § 512] has been predicated upon the nature of the harm for which recovery is sought and not upon the nature of the action brought.”
Capron v. Romeyn, 409 A.2d 565 (Vt. 1979). “Allen, supra, particularly compelling in view of the fact that the legislature has now, in effect, by the amendment to 12 V.S.A. § 512 (4), overruled that case.”
— Vt. Stat. Ann. tit. 12, § 512(5) — 8 cases
Bull v. Pinkham Eng'g Assocs., Inc., 752 A.2d 26 (Vt. 2000). “Statute of Limitations Defendant first contends that plaintiffs’ claim for lost profits is barred by 12 V.S.A. § 512(5), which provides that an action for damage to personal property caused by the act or default of another must be commenced within three years after the cause of…”
Inv. Props., Inc. v. Lyttle, 739 A.2d 1222 (Vt. 1999). “See 12 V.S.A. § 512. Plaintiffs argue that this Court should look to the underlying harm — the damage to the condominiums — in determining the applicable statute of limitations.”
Child.'s Store v. Cody Enter., Inc., 580 A.2d 1206 (Vt. 1990).
Stevers v. ET & HK Ide Co., Inc., 527 A.2d 658 (Vt. 1987).
Foucher v. First Vermont Bank & Trust Co., 821 F. Supp. 916 (D. Vt. 1993).
— Vt. Stat. Ann. tit. 12, § 512(d) — 1 case
A.B. v. S.U., 2023 VT 32 (Vt. 2023). “12 V.S.A. § 512. Under 1 V.S.A. § 214(b)(1), legislative enactments generally do not “affect the operation of the act or provision prior to the effective date of the amendment.”
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