Vermont Statutes Annotated

Vt. Stat. Ann. tit. 14, § 1451 (2026)

✓ current as of May 2026
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Subchapter 002 : SURVIVAL OF CAUSES

(Cite as: 14 V.S.A. § 1451)
Notes of Decisions
Cited in 9 cases (4 in the last 5 years), 1993–2026 · leading case: Est. of Emil Kuhling by Richard W. Kuhling v. Taylor Glaze, 196 A.3d 1125 (Vt. 2018).
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Est. of Emil Kuhling by Richard W. Kuhling v. Taylor Glaze, 196 A.3d 1125 (Vt. 2018). · cites it 2× “The first issue is whether the Estate's claim for breach of fiduciary duty is covered by Vermont's survival statute, 14 V.S.A. § 1451. 3 We determine that the *1130 claim survives Emil's death and the Estate has standing to bring a claim for breach of fiduciary duty.”
Estella McClellan, Adm'r of the Est. of Betty Jo McClellan v. Jeffrey E. Haddock, M.D. & Thomas Chittenden Health Ctr., PLC, 2017 VT 13 (Vt. 2017). “The dissent maintains that, liberally construed, the complaint stated a survival action "for the recovery of damages for a bodily hurt or injury" suffered by the decedent during her lifetime, as provided by 14 V.S.A. §§ 1451 -1452. As noted, however, the complaint expressly…”
Dodge v. Precision Constr. Prods., Inc., 2003 VT 11 (Vt. 2003). · cites it 2× “We conclude that the Act does provide for the survival of the claim, in part, and that the remainder survives under the general survival statute, 14 V.S.A. § 1451, because it has vested. ¶ 5.”
State v. Therrien, 633 A.2d 272 (Vt. 1993). “See 14 V.S.A. §§ 1451 (survival of causes arising out of injury to personal or real property), 1452 (causes arising out of personal injuries), 1453 (actions arising under §§ 1451-1452 may be prosecuted for or against executor or administrator of estate).”
Est. of Donald Crofut v. Sean Hammond (Vt. 2024). · cites it 2× “In asserting that the Estate lacks standing, Hammond fails to address Vermont’s Survival Statute, 14 V.S.A. § 1451, which provides that “[a]ctions .”
New England Youth Theatre, Inc. v. Envtl. Compliance Servs., Inc. (Vt. Super. Ct. 2013). · cites it 3× “Survival of the Causes under 14 V.S.A. § 1451 The next issued raised by Defendant is whether professional negligence and negligent misrepresentation claims survive the death of the original holder of legal title.”
Clough v. Chatfield (Vt. Super. Ct. 2025). “” Moreover, 14 V.S.A. § 1451 allows such actions concerning the conversion, trespass, or for damages to the real or personal Entry Regarding Motion Page 2 of 5 24-CV-05546 Hope Clough et al v.”
Est. of Mayotte v. Dottavio (Vt. Super. Ct. 2026). “Rather, Vermont’s survival statutes, 14 V.S.A. §§ 1451–1455, as they relate to this case, principally describe what underlying claims “survive” the death of the would-be plaintiff.”
Est. of Mayotte v. Dottavio (Vt. Super. Ct. 2026). “Rather, Vermont’s survival statutes, 14 V.S.A. §§ 1451–1455, as they relate to this case, principally describe what underlying claims “survive” the death of the would-be plaintiff.”
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.