Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 521 (2026)

✓ current as of May 2026
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Subchapter 002 : ACTIONS LIMITED

(Cite as: 12 V.S.A. § 521)
Notes of Decisions
Cited in 24 cases (3 in the last 5 years), 1982–2026 · leading case: Lillicrap v. Martin, 591 A.2d 41 (Vt. 1991).
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Lillicrap v. Martin, 591 A.2d 41 (Vt. 1991). · cites it 15× “The plaintiff in this medical malpractice case appeals the action of the trial court granting motions for a directed verdict on behalf of all of the defendants.”
Campbell v. Stafford, 2011 VT 11 (Vt. 2011). · cites it 10× “This motion claimed that the medical malpractice three-year statute of limitations in 12 V.S.A. § 521 barred plaintiffs October 16, 2007, complaint because Dr.”
Stewart v. Darrow, 448 A.2d 788 (Vt. 1982). · cites it 9× “1979 The issue both below and on appeal is which of the three limitation statutes controlled the claim: the original 12 V.”
Fercenia v. Guiduli, 2003 VT 50 (Vt. 2003). · cites it 3× “A § 521, which provides that “actions to recover damages for injuries to the person arising out of any medical or surgical treatment or operation shall be brought within three years of the date of the incident or two years from the date the injury is or reasonably should have…”
Walters v. Cleveland Reg'l Med. Ctr., 307 S.W.3d 292 (Tex. 2010). · cites it 2× “Code Ann § 29-26-116(a)(4) (2009) (exempting foreign-object claims from repose period); Vt. Stat. Ann. tit. 12, § 521 (2009) (exempting foreign-object claims from repose period); Wash.”
Perkins v. Windsor Hosp. Corp., 455 A.2d 810 (Vt. 1982). · cites it 2× “15(c) governs the relation back of amendments, stating: "Whenever the claim ... asserted in the amended pleading arose out of the conduct, transaction, or occurrence set forth or attempted to be set forth in the original pleading, the amendment *816 relates back to the date of…”
Methodist Healthcare Sys. of San Antonio, Ltd., L.L.P., W.C. Schorlemer, M.D., & Robert Schorlemer, M.D. v. Emmalene Rankin, 307 S.W.3d 283 (Tex. 2010). “§ 78 B-3-404(2)(a) (2009); Vt Stat. Ann tit. 12, § 521 (2009); Wash.”
Ware Ex Rel. Ware v. Gifford Mem'l Hosp., 664 F. Supp. 169 (D. Vt. 1987). · cites it 3× “The statute of limitations applicable to this action is 12 V.S.A. § 521, which provides that actions to recover damages for injuries to the person arising out of any medical *170 or surgical treatment or operation shall be brought within three years of the date of the incident…”
Sharond Hill v. Springfield Hosp. & Emergency Servs. of New England, Inc., 2023 VT 23 (Vt. 2023). “The more logical construction of the order is that it gave plaintiff two options once the automatic stay was lifted: file a motion to reopen within thirty days, in which case no additional fees would be incurred, or subsequently refile her complaint as a new action and pay the…”
Univ. of Vermont v. W.R. Grace & Co., 565 A.2d 1354 (Vt. 1989). “§ 518(a) (similar discovery-driven statute of limitations for “radiation injury or injury from other noxious agents medically recognized as having a prolonged latent development”); 12 V.S.A. § 521 (discovery-driven statute of limitations for medical malpractice actions);…”
Inv. Props., Inc. v. Lyttle, 739 A.2d 1222 (Vt. 1999). “, 12 V.S.A. § 521 (two-year limitations for medical malpractice).”
Otis-Wisher v. Fletcher Allen Health Care, Inc., 951 F. Supp. 2d 592 (D. Vt. 2013). “” Vt. Stat. Ann. tit. 12, § 521 . A late-filed claim may also be considered timely if it “relates back” to the date of the original timely pleading.”
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