Vt. Stat. Ann. » Title 12 Chapter 23
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 522 (2026)

✓ current as of May 2026
Find cases: SyfertCases citing this section VT-LEGlegislature.vermont.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

Subchapter 002 : ACTIONS LIMITED

(Cite as: 12 V.S.A. § 522)
Notes of Decisions
Cited in 33 cases (11 in the last 5 years), 1992–2026 · leading case: A.B. v. S.U., 2023 VT 32 (Vt. 2023).
Sort: Relevance Newest Treatment
A.B. v. S.U., 2023 VT 32 (Vt. 2023). · cites it 8× “Defendants 2 now bring this interlocutory appeal to determine whether 12 V.S.A. § 522 violates Chapter I, Article 4 of the Vermont Constitution by reviving an otherwise time-barred claim of childhood sexual abuse.”
Earle v. State, 743 A.2d 1101 (Vt. 1999). · cites it 5× “The error lay in failing to consider when plaintiff discovered his “injury or condition was caused by the act of sexual abuse,” for purposes of the retroactivity provision in 12 V.S.A. § 522. The trial court failed to recognize that a plaintiff alleging injuries from childhood…”
Doe v. Archdiocese of Milwaukee, 565 N.W.2d 94 (Wis. 1997). · cites it 2× “1997) (court must find reasonable and meritorious cause for filing action before defendant may be named in petition); Vt. Stat. Ann. tit. 12, § 522 (b) (West Supp.”
Turner v. Roman Catholic Diocese, 2009 VT 101 (Vt. 2009). “12 V.S.A. § 522(a). The statute includes a retroactivity provision that applies § 522(a) to “all causes of action commenced on or after the effective date of this act, so long as either the act of sexual abuse or the discovery that the injury or condition was caused by the act…”
Moriarty v. Garden Sanctuary Church of God, 511 S.E.2d 699 (S.C. Ct. App. 1999). · cites it 2× “1994); Vt.Stat.Ann. tit. 12, §§ 522, 560 (Supp.1994); Va.”
Shovah v. Mercure, 44 F. Supp. 3d 504 (D. Vt. 2014). · cites it 2× “Shovah’s First Amended Complaint seeks to add a cause of action under Vermont law regarding the same conduct already alleged in the original complaint—specifically, Vt. Stat. Ann. tit. 12, § 522 . Plaintiffs motion to amend is therefore a conceded attempt to maintain his action…”
Clarke v. Abate, 2013 VT 52 (Vt. 2013). · cites it 2× “The parties and the trial court agree that the applicable statute of limitations is found in 12 V.S.A. § 522(a), which states as follows: A civil action brought by any person for recovery of damages for injury suffered as a result of childhood sexual abuse shall be commenced…”
Eaton v. Prior, Belmay & Vermont State Police, 2012 VT 54 (Vt. 2012). · cites it 2× “2 In rejecting the claim relating to 12 V.S.A. § 522, the trial court ruled that defendants here neither caused nor facilitated the sexual abuse, and therefore were not subject to the statute.”
S.V. v. R.V., 933 S.W.2d 1 (Tex. 1996). “1995); Vt.Stat.Ann. tit. 12, § 522 (Michie Supp.”
Almonte v. New York Med. Coll., 851 F. Supp. 34 (D. Conn. 1994). “1 (action within 4 years of majority or discovery); Vt.Stat.Ann. tit. 12, § 522 (action within 6 years of injury of discovery); Va.”
Doe v. Rd & Ed, 417 S.E.2d 541 (S.C. 1992). “Section 27-2-216 (1989); Vt. Stat. Ann. tit. 12, Section 522 (1990) and Vt.”
Doe v. Doe, 768 A.2d 1291 (Vt. 2001). “* Because the file below was sealed pursuant to 12 V.S.A. § 522(b), pseudonyms are used for defendants B.”
Show all 33 citing cases →
— Vt. Stat. Ann. tit. 12, § 522(a) — 12 cases
Turner v. Roman Catholic Diocese, 2009 VT 101 (Vt. 2009). “12 V.S.A. § 522(a). The statute includes a retroactivity provision that applies § 522(a) to “all causes of action commenced on or after the effective date of this act, so long as either the act of sexual abuse or the discovery that the injury or condition was caused by the act…”
Clarke v. Abate, 2013 VT 52 (Vt. 2013). “The parties and the trial court agree that the applicable statute of limitations is found in 12 V.S.A. § 522(a), which states as follows: A civil action brought by any person for recovery of damages for injury suffered as a result of childhood sexual abuse shall be commenced…”
Earle v. State, 743 A.2d 1101 (Vt. 1999). “The error lay in failing to consider when plaintiff discovered his “injury or condition was caused by the act of sexual abuse,” for purposes of the retroactivity provision in 12 V.S.A. § 522. The trial court failed to recognize that a plaintiff alleging injuries from childhood…”
Eaton v. Prior, Belmay & Vermont State Police, 2012 VT 54 (Vt. 2012). “2 In rejecting the claim relating to 12 V.S.A. § 522, the trial court ruled that defendants here neither caused nor facilitated the sexual abuse, and therefore were not subject to the statute.”
Whitwell v. Archmere Academy, Inc., 463 F. Supp. 2d 482 (D. Del. 2006).
— Vt. Stat. Ann. tit. 12, § 522(b) — 6 cases
A.B. v. S.U., 2023 VT 32 (Vt. 2023). “Defendants 2 now bring this interlocutory appeal to determine whether 12 V.S.A. § 522 violates Chapter I, Article 4 of the Vermont Constitution by reviving an otherwise time-barred claim of childhood sexual abuse.”
Doe v. Doe, 768 A.2d 1291 (Vt. 2001). “* Because the file below was sealed pursuant to 12 V.S.A. § 522(b), pseudonyms are used for defendants B.”
Haynes v. Haggerty (D. Vt. 2020).
Milazzo v. Anthony (D. Vt. 2024).
milazzo v. rossi (Vt. Super. Ct. 2024).
— Vt. Stat. Ann. tit. 12, § 522(c) — 2 cases
Haynes v. Haggerty (D. Vt. 2020).
Ks v. Dcf (Vt. Super. Ct. 2025).
— Vt. Stat. Ann. tit. 12, § 522(c)(1) — 1 case
Doe v. New Eng Kern Hattin Homes (Vt. Super. Ct. 2025).
— Vt. Stat. Ann. tit. 12, § 522(d) — 3 cases
A.B. v. S.U., 2023 VT 32 (Vt. 2023). “Defendants 2 now bring this interlocutory appeal to determine whether 12 V.S.A. § 522 violates Chapter I, Article 4 of the Vermont Constitution by reviving an otherwise time-barred claim of childhood sexual abuse.”
Emmons v. Hinesburg (Vt. Super. Ct. 2026).
Doe v. New Eng Kern Hattin Homes (Vt. Super. Ct. 2025).
— Vt. Stat. Ann. tit. 12, § 522(e) — 1 case
Doe v. New Eng Kern Hattin Homes (Vt. Super. Ct. 2025).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.