Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 519 (2026)

✓ current as of May 2026
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Subchapter 002 : ACTIONS LIMITED

(Cite as: 12 V.S.A. § 519)
Notes of Decisions
Cited in 25 cases, 1981–2018 · leading case: Sabia v. State, 669 A.2d 1187 (Vt. 1995).
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Sabia v. State, 669 A.2d 1187 (Vt. 1995). · cites it 2× “Even if SRS did not “undertake” to help plaintiffs, 12 V.S.A. § 519 provides a private analog for the present action.”
Kennery v. State of Vermont, Valcourt, LaBombard & Other Members of the Dept. of Pub. Saf., 2011 VT 121 (Vt. 2011). · cites it 2× “The court also rejected finding a duty under the Vermont emergency medical care or “good Samaritan” statute, 12 V.S.A. § 519, or under a common law theory based on § 324 of the Restatement (Second) of Torts (as opposed to § 324A).”
Iseberg v. Gross, 879 N.E.2d 278 (Ill. 2007). “7 7 A Vermont statute (12 Vt. Stat. Ann. tit. 12, §519 (2002)) provides for a civil cause of action if a rescuer, in providing assistance, acts with gross negligence, but the statute does not recognize a civil cause of action for the failure to give reasonable assistance.”
Hardingham v. United Counseling Serv. of Bennington Cnty., Inc., 672 A.2d 480 (Vt. 1995). · cites it 3× “Defendants sought summary judgment. The superior court granted their motions based on its conclusion that, as a matter of law given the facts of the case, (1) Vermont’s Duty to Aid the Endangered Act, 12 V.”
Kaho'ohanohano ex rel. Morales-Kaho'ohanohano v. Dep't of Human Servs., 178 P.3d 538 (Haw. 2008). “The court also observed that a private analog can also be found in the state's emergency medical care (duty to assist) statute, 12 V.S.A. § 519. Id. at 1194. Section 519 provides in relevant part that: (a) A person who knows that another person is exposed to grave physical harm…”
Kane v. Lamothe, 182 Vt. 241 (Vt. 2007). “" 12 V.S.A. § 519. The statute is not applicable in this case because the facts alleged do not support a finding that trooper knew that plaintiff was exposed to grave physical harm.”
Earle v. State, 2006 VT 92 (Vt. 2006). · cites it 2× “We also found an analog under Vermont's good samaritan statute, 12 V.S.A. § 519, pursuant to the Restatement (Second) of Torts § 324, referencing "a duty of care upon those who take charge of helpless persons," and Restatement (Second) of Torts § 315(b), articulating a duty to…”
Baptie v. Bruno & McNeil, 88 A.3d 1212 (Vt. 2013). “Nor could an officer in defendant’s position reasonably have believed that his actions in investigating plaintiffs’ complaint violated Vermont’s Good Samaritan Act, 12 V.S.A. § 519(a), or a duty to protect John Baptie.”
Est. of Cilley v. Lane, 2009 ME 133 (Me. 2009). “); Ohio Rev.Code. Ann. § 2921.22 (LEXIS through Nov.”
Lynne Stockberger, Both Personally & as the Rep. of Maurice Stockberger, Deceased v. United States, 332 F.3d 479 (7th Cir. 2003). “, Vt. Stat. Ann. tit. 12, § 519 (a); Melvin A.”
Kane v. Lamothe, 2007 VT 91 (Vt. 2007). “" 12 V.S.A. § 519 (a). The statute is not applicable in this case because the facts alleged do not support a finding that trooper knew that plaintiff was exposed to grave physical harm.”
Smith v. Day, 538 A.2d 157 (Vt. 1987). “, Duty to Aid the Endangered Act, 12 V.S.A. § 519(a) (“A person who knows that another is exposed to grave physical harm shall.”
Show all 25 citing cases →
— Vt. Stat. Ann. tit. 12, § 519(a) — 10 cases
Sabia v. State, 669 A.2d 1187 (Vt. 1995). “Even if SRS did not “undertake” to help plaintiffs, 12 V.S.A. § 519 provides a private analog for the present action.”
Baptie v. Bruno & McNeil, 88 A.3d 1212 (Vt. 2013). “Nor could an officer in defendant’s position reasonably have believed that his actions in investigating plaintiffs’ complaint violated Vermont’s Good Samaritan Act, 12 V.S.A. § 519(a), or a duty to protect John Baptie.”
Smith v. Day, 538 A.2d 157 (Vt. 1987). “, Duty to Aid the Endangered Act, 12 V.S.A. § 519(a) (“A person who knows that another is exposed to grave physical harm shall.”
Hardingham v. United Counseling Serv. of Bennington Cnty., Inc., 672 A.2d 480 (Vt. 1995). “Defendants sought summary judgment. The superior court granted their motions based on its conclusion that, as a matter of law given the facts of the case, (1) Vermont’s Duty to Aid the Endangered Act, 12 V.”
State v. Joyce, 433 A.2d 271 (Vt. 1981).
— Vt. Stat. Ann. tit. 12, § 519(c) — 1 case
Hardingham v. United Counseling Serv., 667 A.2d 289 (Vt. 1995).
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