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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 892 (2026)

✓ current as of May 2026
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Subchapter 007 : OPERATORS OF MOTOR VEHICLES

(Cite as: 12 V.S.A. § 892)
Notes of Decisions
Cited in 11 cases (1 in the last 5 years), 1970–2024 · leading case: Michael D. Messier v. Kay H. Bushman & The Stand. Fire Ins. Co. d/b/a Travelers, 197 A.3d 882 (Vt. 2018).
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Michael D. Messier v. Kay H. Bushman & The Stand. Fire Ins. Co. d/b/a Travelers, 197 A.3d 882 (Vt. 2018). · cites it 8× “In relevant part, 12 V.S.A. § 892(a) requires that: a copy of the process be left at the Commissioner's office along with a $15 fee; a copy of the process with the officer's return showing service upon the Commissioner be sent by plaintiff to defendant by registered or certified…”
Thayer v. Herdt, 586 A.2d 1122 (Vt. 1990). · cites it 2× “Plaintiff correctly points out that, in obvious response to the holding in Law’s Administrator , the Legislature amended 12 V.S.A. § 892 in 1961 to provide that service on the Commissioner of Motor Vehicles shall not render inoperative the tolling provisions of 12 V.”
Ricker v. Lajoie, 314 F. Supp. 401 (D. Vt. 1970). “This is a suit for injuries sustained in an automobile collision on March 2, 1966, in Barnet, Vermont, served on the defendant by serving the commissioner of motor vehicles on November 4, 1969, under 12 V.S.A. § 892. Defendant has pleaded in bar the three-year statute of…”
Andrews v. Stam, 2007 VT 79 (Vt. 2007). “Plaintiff, with new counsel, filed the present case on December 6, 2005, and effectuated service on December 8, 2005, by serving the Vermont Commissioner of Motor Vehicles pursuant to 12 V.S.A. §892. ¶ 3. Defendant, in his motion to dismiss, maintained that plaintiffs second…”
Mintz v. Matalon, 535 A.2d 783 (Vt. 1987). “It is undisputed, however, that plaintiff did not send defendant a copy of the process and return by registered mail, as required by 12 V.S.A. § 892(a). Defendant only learned of the existence of the suit when plaintiff’s attorney telephoned him on April 23, 1985, stating that…”
Andrews v. Stam, 182 Vt. 482 (Vt. 2007). “Plaintiff, with new counsel, filed the present case on December 6, 2005, and effectuated service on December 8, 2005 by serving the Vermont Commissioner of Motor Vehicles pursuant to 12 V.S.A. § 892. ¶ 3. Defendant, in his motion to dismiss, maintained that plaintiff's second…”
Messier v. Bushman (Vt. Super. Ct. 2017). · cites it 3× “June 9, 2016) (noting that failure to strictly adhere to requirements of 12 V.S.A. § 892 led to dismissal in trial court).”
Cutler v. Travelers Ins., 412 A.2d 284 (Vt. 1980). “Uncontested service on defendant Graveline was made on the Commissioner of Motor Vehicles as his designated *115 agent pursuant to 12 V.S.A. § 892 on December 9, 1975. The applicable period of limitations here is three years.”
Bashara v. Corliss, 632 A.2d 30 (Vt. 1993). “On November 7, 1988, plaintiff served the complaint against defendant upon the Commissioner of Motor Vehicles, pursuant to 12 V.S.A. § 892. Thus, service was made within sixty days of the filing of the original complaint.”
Patriot Mut Ins Co v. Welch (Vt. Super. Ct. 2024). “12 V.S.A. § 892(a). Vermont’s statute does not specify what the affidavit of compliance must say about whether the registered or certified mail was delivered or returned as undeliverable, or whether the affidavit must be accompanied by the return receipt.”
Taft-Blakely v. Reinhart Foodservice, LLC (Vt. Super. Ct. 2015). “12 V.S.A. § 892 (service on Commissioner is sufficient if a copy is sent to the defendant “by registered or certified mail, and .”
— Vt. Stat. Ann. tit. 12, § 892(a) — 4 cases
Michael D. Messier v. Kay H. Bushman & The Stand. Fire Ins. Co. d/b/a Travelers, 197 A.3d 882 (Vt. 2018). “In relevant part, 12 V.S.A. § 892(a) requires that: a copy of the process be left at the Commissioner's office along with a $15 fee; a copy of the process with the officer's return showing service upon the Commissioner be sent by plaintiff to defendant by registered or certified…”
Mintz v. Matalon, 535 A.2d 783 (Vt. 1987). “It is undisputed, however, that plaintiff did not send defendant a copy of the process and return by registered mail, as required by 12 V.S.A. § 892(a). Defendant only learned of the existence of the suit when plaintiff’s attorney telephoned him on April 23, 1985, stating that…”
Messier v. Bushman (Vt. Super. Ct. 2017). “June 9, 2016) (noting that failure to strictly adhere to requirements of 12 V.S.A. § 892 led to dismissal in trial court).”
Patriot Mut Ins Co v. Welch (Vt. Super. Ct. 2024). “12 V.S.A. § 892(a). Vermont’s statute does not specify what the affidavit of compliance must say about whether the registered or certified mail was delivered or returned as undeliverable, or whether the affidavit must be accompanied by the return receipt.”
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