Vermont Statutes Annotated

Vt. Stat. Ann. tit. 14, § 1491 (2026)

✓ current as of May 2026
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Subchapter 003 : WRONGFUL DEATH

(Cite as: 14 V.S.A. § 1491)
Notes of Decisions
Cited in 18 cases (3 in the last 5 years), 1976–2026 · leading case: Tatum v. Schering Corp., 523 So. 2d 1042 (Ala. 1988).
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Tatum v. Schering Corp., 523 So. 2d 1042 (Ala. 1988). · cites it 6× “Stat. § 30.020 (1983); 42 Pa.Cons.Stat. Ann.”
Peterson v. Islamic Repub. of Iran, 515 F. Supp. 2d 25 (D.D.C. 2007). · cites it 2× “§ 15-51-10 (2006); Vt. Stat. Ann. tit. 14, § 1491 (2007). Each statute -provides for recovery of numerous categories of damages, including pecuniary loss in the form of the present monetary value of the decedent to the persons entitled to receive the damages recovered, expenses…”
Vaillancourt v. Med. Ctr. Hosp. of Vermont, Inc., 425 A.2d 92 (Vt. 1980). · cites it 3× “Wrongful death of the fetus under 14 V.S.A. §§ 1491, 1492, by action of Mr.”
Bacon v. Lascelles, 678 A.2d 902 (Vt. 1996). “8 Plaintiff also argues that the trial court erred by ruling that she is not “next-of-kin” under the Wrongful Death Act, 14 VS.A. § 1491,' and erred in its jury instruction regarding the decedent’s contributory negligence.”
Scheele v. Dustin, 2010 VT 45 (Vt. 2010). · cites it 2× “Toward this end, they request that this Court extend the common law to permit such damages to the degree that they are not otherwise recognized in our jurisprudence.”
Thayer v. Herdt, 586 A.2d 1122 (Vt. 1990). “14 V.S.A. §§ 1491, 1492. Plaintiff does not argue that the remedy is inadequate.”
Goodby v. Vetpharm, Inc., 2009 VT 52 (Vt. 2009). “See 14 V.S.A. §§ 1491, 1492(b) (enabling recovery by parent for the “loss of love and companionship” of a deceased child and “for destruction of the parent-child relationship”); Dubaniewicz v.”
State v. Oliver, 563 A.2d 1002 (Vt. 1989). “would make no sense to determine a child’s personhood, for purposes of being the victim of a crime, by reference to which side of the birth canal the child is on at the time of its victimization.”
Quesnel v. Town of Middlebury, 706 A.2d 436 (Vt. 1997). “14 V.S.A. § 1491. The procedure for such an action is set forth in 14 V.”
Fortunati v. Campagne, 681 F. Supp. 2d 528 (D. Vt. 2009). “Vt. Stat. Ann. tit. 14, § 1491 (2008). The decedent’s estate must still allege and prove a traditional claim for injury — in state tort law or otherwise' — in order to recover.”
Merrill v. Reville, 380 A.2d 96 (Vt. 1977). “The complaint sought to recover damages under the provisions of our wrongful death statute, 14 V.S.A. § 1491, and for bodily hurt caused by the act or default of another, a survival action authorized by 14 V.”
Johnson v. Hoisington, 367 A.2d 680 (Vt. 1976). “The right of the personal representative to maintain this action is based on the provisions of 14 V.S.A. §§ 1491 and 1492. The amount of recovery is to be distributed among the next of kin and spouse, if any, in proportion to the pecuniary injuries suffered on account of the…”
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