Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 552 (2026)

✓ current as of May 2026
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Subchapter 003 : COMPUTATION OF TIME; TOLLING OF STATUTE

(Cite as: 12 V.S.A. § 552)
Notes of Decisions
Cited in 10 cases (1 in the last 5 years), 1970–2024 · leading case: Fortier v. Byrnes, 678 A.2d 890 (Vt. 1996).
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Fortier v. Byrnes, 678 A.2d 890 (Vt. 1996). · cites it 9× “In his response, plaintiff argued that the statute was tolled under 12 V.S.A. § 552 3 because defendant had resided out of state during the time between plaintiff’s injury and the date of the complaint.”
Thayer v. Herdt, 586 A.2d 1122 (Vt. 1990). · cites it 3× “§ 892 in 1961 to provide that service on the Commissioner of Motor Vehicles shall not render inoperative the tolling provisions of 12 V.S.A. § 552 — which are virtually identical to those found in 14 V.”
Marine Midland Bank v. Bicknell, 2004 VT 25 (Vt. 2004). · cites it 4× “The court found that § 506 applied and that, contrary to appellant’s assertion, Vermont’s tolling statute, 12 V.S.A. § 552, did not extend to this action because both parties were New York residents when the cause of action accrued.”
Ricker v. Lajoie, 314 F. Supp. 401 (D. Vt. 1970). · cites it 3× “The issue before the Court, is, therefore, whether an automobile insurance policy issued to a non-resident by a company doing business in Vermont is “known property within the state” of Vermont “which can, by common process of law, be attached” within 12 V.”
Martel v. Stafford, 603 A.2d 345 (Vt. 1991). “Based on this fact he argued that the applicable statute of limitations was tolled until that date pursuant to 12 V.S.A. § 552. If we accept that argument, the complaint was untimely by only four and one-half months.”
Andrews v. Stam, 182 Vt. 482 (Vt. 2007). · cites it 2× “Rather, plaintiff argues that the statute of limitations was tolled by 12 V.S.A. § 552, which provides: If a person is absent from and resides out of the state after a cause of action accrues against him and before the statute has run, and he has not known property within the…”
Andrews v. Stam, 2007 VT 79 (Vt. 2007). “Rather, plaintiff argues that the statute of limitations was tolled by 12 V.S.A. § 552, which provides: *484 If a person is absent from and resides out of the state after a cause of action accrues against him and before the statute has run, and he has not known property within…”
Messier v. Bushman (Vt. Super. Ct. 2017). · cites it 3× “§ 558 Regardless of whether the court should have dismissed rather than having granted judgment on the pleadings, nothing in the record suggests that 12 V.”
messier v. bushman (Vt. Super. Ct. 2024). · cites it 2× “§ 558 Regardless of whether the court should have dismissed rather than having granted judgment on the pleadings, nothing in the record suggests that 12 V.S.A. § 558 applies to this case and Mr. Messier does not explain how it could.”
Cutler v. Travelers Ins., 412 A.2d 284 (Vt. 1980). “Plaintiffs’ claim would be barred but the statute is tolled pursuant to 12 V.S.A. §§ 552, 892(b). Although the court below erred in dismissing the action against the defendant Graveline on the basis of the statute of limitations, the error was harmless.”
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