Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 558 (2026)

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

(Cite as: 12 V.S.A. § 558)
Notes of Decisions
Cited in 23 cases (6 in the last 5 years), 1965–2025 · leading case: Michael Quinlan, of the Est. of Lincy Sullivan v. Five-Town Health All., Inc., dba Mountain Health Ctr. & Sean May, PA-C, 192 A.3d 390 (Vt. 2018).
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Michael Quinlan, of the Est. of Lincy Sullivan v. Five-Town Health All., Inc., dba Mountain Health Ctr. & Sean May, PA-C, 192 A.3d 390 (Vt. 2018). · cites it 4× “1 He also argued that dismissal would violate his right to equal protection under the Vermont and United States Constitutions and that the statute of limitations was otherwise tolled by 12 V.S.A. § 558. ¶ 9. On March 8, 2017, the trial court dismissed Quinlan II with prejudice,…”
Jane Doe v. Victoria Camacho, 2024 VT 72 (Vt. 2024). · cites it 5× “Plaintiff argues that, given the circumstances surrounding the dismissal of those claims, the trial court erred in concluding that the instant complaint was not timely filed under Vermont’s savings statute, 12 V.S.A. § 558, or, in the alternative, pursuant to the equitable-…”
Leno v. Meunier, 209 A.2d 485 (Vt. 1965). · cites it 7× “ntiff replied to this motion that a previous suit was seasonably brought on August 16, 1960 in the United States District Court for Vermont; that the writ was dismissed by the District Court on June 17, 1961 without trial on the merits for the lack of jurisdiction and that this…”
Michael D. Messier v. Kay H. Bushman & The Stand. Fire Ins. Co. d/b/a Travelers, 197 A.3d 882 (Vt. 2018). “We decline to address Messier's arguments concerning the potential application of 12 V.S.A. § 558, which pertains to commencement of a new action following the failure of an original action under certain circumstances.”
Weisburgh v. McClure Newspapers, Inc., 396 A.2d 1388 (Vt. 1979). · cites it 2× “As the order dismissing this complaint points out, if the filing of a complaint is to be effective in tolling the statute of limitations as of that filing date, timely service under the Rules of Civil Procedure must be accomplished.”
Leo v. Hillman, 665 A.2d 572 (Vt. 1995). “As we said of 12 V.S.A. § 558, in language equally applicable to 12 V.”
Oppenheim v. Hutchinson, 926 A.2d 177 (Me. 2007). “2d 389, 390 (1942) (interpreting an earlier version of VT. STAT. ANN. tit. 12, § 558 (2002), which mirrored the current version of Maine’s saving statute).”
Shovah v. Mercure, 44 F. Supp. 3d 504 (D. Vt. 2014). “See Vt. Stat. Ann. tit. 12, § 558 (“[A] plaintiff may commence a new action for the same cause within one year after the determination of the original action, when the original action has been commenced within the time limited by any statute of this state, .”
Shortle v. Bd. of Zoning Adjustment, 388 A.2d 430 (Vt. 1978). “Subsequently, by various motions made and denied, plaintiffs asked the Superior Court to have their appeal time extended, or their declaratory judgment complaint treated as a notice of appeal, and for relief under 12 V.S.A. § 558, V.R.C.P. 60(b), and other related rules.”
Schulman v. Saloon Beverage, Inc., 991 F. Supp. 2d 501 (D. Vt. 2014). · cites it 7× “First, they suggest that their cause of action accrued on or after July 3, 2011 — or at least that it is impossible at present to conclude otherwise.”
gates v. mack molding (Vt. Super. Ct. 2024). · cites it 4× “Gates also raises a separate legal issue: whether under 12 V.S.A. § 558, the operative or effective date of filing should be the date on which he filed his FEPA and WCA retaliation claims in federal court (May 6, 2022), rather than the date that such claims were filed in this…”
Messier v. Bushman (Vt. Super. Ct. 2017). · cites it 4× “Messier; (2) the court improperly relied on extra-pleading materials in analyzing the effectiveness of service; and (3) the court failed to consider the possibility of tolling pursuant to 12 V.S.A. § 552. Mr. Messier raises each of these issues for the first time post-judgment.”
Show all 23 citing cases →
— Vt. Stat. Ann. tit. 12, § 558(2) — 1 case
Leno v. Meunier, 209 A.2d 485 (Vt. 1965). “ntiff replied to this motion that a previous suit was seasonably brought on August 16, 1960 in the United States District Court for Vermont; that the writ was dismissed by the District Court on June 17, 1961 without trial on the merits for the lack of jurisdiction and that this…”
— Vt. Stat. Ann. tit. 12, § 558(a) — 7 cases
Michael Quinlan, of the Est. of Lincy Sullivan v. Five-Town Health All., Inc., dba Mountain Health Ctr. & Sean May, PA-C, 192 A.3d 390 (Vt. 2018). “1 He also argued that dismissal would violate his right to equal protection under the Vermont and United States Constitutions and that the statute of limitations was otherwise tolled by 12 V.S.A. § 558. ¶ 9. On March 8, 2017, the trial court dismissed Quinlan II with prejudice,…”
Weisburgh v. McClure Newspapers, Inc., 396 A.2d 1388 (Vt. 1979). “As the order dismissing this complaint points out, if the filing of a complaint is to be effective in tolling the statute of limitations as of that filing date, timely service under the Rules of Civil Procedure must be accomplished.”
Schulman v. Saloon Beverage, Inc., 991 F. Supp. 2d 501 (D. Vt. 2014). “First, they suggest that their cause of action accrued on or after July 3, 2011 — or at least that it is impossible at present to conclude otherwise.”
messier v. bushman (Vt. Super. Ct. 2024).
Messier v. Bushman (Vt. Super. Ct. 2017). “Messier; (2) the court improperly relied on extra-pleading materials in analyzing the effectiveness of service; and (3) the court failed to consider the possibility of tolling pursuant to 12 V.S.A. § 552. Mr. Messier raises each of these issues for the first time post-judgment.”
— Vt. Stat. Ann. tit. 12, § 558(a)(1) — 2 cases
Jane Doe v. Victoria Camacho, 2024 VT 72 (Vt. 2024). “Plaintiff argues that, given the circumstances surrounding the dismissal of those claims, the trial court erred in concluding that the instant complaint was not timely filed under Vermont’s savings statute, 12 V.S.A. § 558, or, in the alternative, pursuant to the equitable-…”
Joseph v. Dartmouth-Hitchcock Clinic (Vt. Super. Ct. 2016).
— Vt. Stat. Ann. tit. 12, § 558(a)(2) — 5 cases
HARR, LLC v. Town of Northfield (Vt. Super. Ct. 2020).
Barrett v. Prison Health Servs., Inc., 647 F. Supp. 2d 314 (D. Vt. 2009).
gates v. mack molding (Vt. Super. Ct. 2024). “Gates also raises a separate legal issue: whether under 12 V.S.A. § 558, the operative or effective date of filing should be the date on which he filed his FEPA and WCA retaliation claims in federal court (May 6, 2022), rather than the date that such claims were filed in this…”
Cote v. Anr (Vt. Super. Ct. 2025).
Stephen Bain v. Peter Potanas, William Lawhorn & Andrew Pallito (Vt. 2012).
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