Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 557 (2026)

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

(Cite as: 12 V.S.A. § 557)
Notes of Decisions
Cited in 19 cases (2 in the last 5 years), 1963–2024 · leading case: Martel v. Stafford, 603 A.2d 345 (Vt. 1991).
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Martel v. Stafford, 603 A.2d 345 (Vt. 1991). · cites it 12× “The Rutland Superior Court dismissed the action as filed beyond the limitation period imposed by 12 V.S.A. § 557(a), and this appeal followed.”
Benson v. MVP Health Plan, Inc., 2009 VT 57 (Vt. 2009). · cites it 3× “MVP moved to dismiss, arguing that the claim was barred by the two-year limitations period set forth in 12 V.S.A. § 557(a). That statute reads as follows: If a person, by or against whom an action may be brought, dies before the expiration of the time within which such action…”
Leo v. Hillman, 665 A.2d 572 (Vt. 1995). · cites it 3× “The court disagreed, concluding that the matter was governed by 12 V.S.A. § 557(a) (Death of a party), which states: If a person, by or against whom an action may be brought, dies before the expiration of the time within which such action may be commenced as provided by this…”
In Re Est. of Peters, 765 A.2d 468 (Vt. 2000). · cites it 3× “See 12 V.S.A. § 557(a). Plaintiff implicitly concedes the applicability of the limitation, but contends that the statute of limitations has been waived in this case by defendant’s failure to assert it.”
Est. of Harris v. Eichel, 565 A.2d 1281 (Vt. 1988). · cites it 3× “The trial court’s decision was based on 12 V.S.A. § 557(a), which states: (a) If a person, by or against whom an action may be brought, dies before the expiration of the time within which such action may be commenced as provided by this chapter or dies within thirty days after…”
Mier's Admr. v. Boyer, 196 A.2d 501 (Vt. 1963). · cites it 3× “§§1451-1452 and 12 V.S.A. §557. He argues that since the legislature has by the enactment of 12 V.”
Pike v. Chuck's Willoughby Pub, Inc., 2006 VT 54 (Vt. 2006). “See 12 V.S.A. § 557(a) (tolling limitations period for time between decedent’s death and the appointment of administrator of decedent’s estate).”
Merrill v. Reville, 380 A.2d 96 (Vt. 1977). “§ 1492 which requires a wrongful death action to be commenced within two years from the death of plaintiff’s intestate and by 12 V.S.A. § 557 which provides that a survival action may be commenced by an administrator within two years after the issuance of letters of…”
Parent v. Beeman, 420 A.2d 866 (Vt. 1980). · cites it 7× “Since this is a wrongful death action and not one for injuries sustained prior to death, it follows that 12 V.S.A. § 557 (a) does not apply to the case at bar, and that certified questions (2) and (3) must be answered in the negative.”
Jakeway ex rel. Est. of Jakeway v. Siva (Vt. Super. Ct. 2012). · cites it 9× “Plaintiffs (the Administratrix of the Estate and the decedent’s wife, who asserts a loss of consortium claim) assert that because this is a survival action, their suit is timely filed under 12 V.S.A. § 557(a), as it was commenced within two years of the appointment of an…”
Schulman v. Saloon Beverage, Inc., 991 F. Supp. 2d 501 (D. Vt. 2014). · cites it 2× “2d 866 (1980), a wrongful-death case in which the Court concluded that the tolling provision in 12 V.S.A. § 557(a) was not available to toll the two-year limitations period under the wrongful death statute, both because of the language of the tolling provision itself, and by…”
C. Wayne Clark v. Richard A. DiStefano, 195 A.3d 379 (Vt. 2018). “§ 464, contained in the same chapter (Chapter 23) with 12 V.S.A. § 557(a). That section reads: ".”
Show all 19 citing cases →
— Vt. Stat. Ann. tit. 12, § 557(a) — 15 cases
Martel v. Stafford, 603 A.2d 345 (Vt. 1991). “The Rutland Superior Court dismissed the action as filed beyond the limitation period imposed by 12 V.S.A. § 557(a), and this appeal followed.”
Benson v. MVP Health Plan, Inc., 2009 VT 57 (Vt. 2009). “MVP moved to dismiss, arguing that the claim was barred by the two-year limitations period set forth in 12 V.S.A. § 557(a). That statute reads as follows: If a person, by or against whom an action may be brought, dies before the expiration of the time within which such action…”
Leo v. Hillman, 665 A.2d 572 (Vt. 1995). “The court disagreed, concluding that the matter was governed by 12 V.S.A. § 557(a) (Death of a party), which states: If a person, by or against whom an action may be brought, dies before the expiration of the time within which such action may be commenced as provided by this…”
In Re Est. of Peters, 765 A.2d 468 (Vt. 2000). “See 12 V.S.A. § 557(a). Plaintiff implicitly concedes the applicability of the limitation, but contends that the statute of limitations has been waived in this case by defendant’s failure to assert it.”
Est. of Harris v. Eichel, 565 A.2d 1281 (Vt. 1988). “The trial court’s decision was based on 12 V.S.A. § 557(a), which states: (a) If a person, by or against whom an action may be brought, dies before the expiration of the time within which such action may be commenced as provided by this chapter or dies within thirty days after…”
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