Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 551 (2026)

✓ current as of May 2026
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Subchapter 002 : DIVORCE

(Cite as: 15 V.S.A. § 551)
Notes of Decisions
Cited in 34 cases, 1967–2018 · leading case: Emmons v. Emmons, 450 A.2d 1113 (Vt. 1982).
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Emmons v. Emmons, 450 A.2d 1113 (Vt. 1982). · cites it 16× “15 V.S.A. § 551(4). It seems likely, therefore, that the trial court employed "abandoned" in its broader, generic sense, that is, to forsake, leave, or desert, "as a person to whom one owes [a] duty.”
Nickerson v. Nickerson, 605 A.2d 1331 (Vt. 1992). · cites it 4× “Nevertheless, mere physical custody by one of two fit parents, during the time the estranged spouses live "apart" to satisfy the no-fault divorce requirements, should not in itself cause a former primary-care-provider to lose that status.”
Michael D.C. v. Wanda L.C., 497 S.E.2d 531 (W. Va. 1997). “§ 30-3-1 (3)(b) (1995); Vt. Stat. Ann. tit. 15, § 551 (1) (1989); Va.”
LeBlanc v. LeBlanc, 2014 VT 65 (Vt. 2014). · cites it 2× “See 15 V.S.A. § 551(7). ¶ 17. Mother moved for reconsideration, challenging the court’s custody award and its visitation schedule.”
Conley v. Crisafulli, 2010 VT 38 (Vt. 2010). “See 15 V.S.A. § 551(7) (stating that divorce may be granted “[w]hen a married person has lived apart from his or her spouse for six consecutive months and the court finds that the resumption of marital relations is not reasonably probable”).”
Scott v. Scott, 586 A.2d 1140 (Vt. 1990). · cites it 2× “Plaintiff had initially filed for divorce by alleging an anticipatory separation, meaning that by the time of the final hearing the six-month living apart period required by 15 V.S.A. § 551(7) would have occurred. At the hearing on the motion to expedite, plaintiff represented…”
Johnson v. Johnson, 580 A.2d 503 (Vt. 1990). “The court granted the divorce on the ground that the parties had lived separate and apart for a period in excess of six months and a resumption of marital relations was not reasonably probable, in accordance with 15 V.S.A. § 551(7). The court accepted the parties’ stipulation…”
Samis v. Samis, 2011 VT 21 (Vt. 2011). “Following evidentiary hearings on the matter of the divorce, the court granted the no-fault divorce petition under 15 V.S.A. § 551(7), finding that the guardian, on behalf of wife, established that she and husband had “lived separate and apart for a period of six consecutive…”
Krupp v. Krupp, 236 A.2d 653 (Vt. 1967). “15 V.S.A. §551(7). The case is here on appeal by the libelant from findings of fact and the judgmexit order of the court dismissing the libel.”
DeGrace v. DeGrace, 520 A.2d 987 (Vt. 1986). “15 V.S.A. § 551(7). A final order and judgment were issued on August 1, 1984.”
Buttura v. Buttura, 463 A.2d 229 (Vt. 1983). “15 V.S.A. § 551 (7). Although defendant does not contest the issuance of the divorce, he does contest the trial court’s order directing him to pay plaintiff $15,000, in six installments of $2,500 each, “in full satisfaction of all claims for alimony, property settlement and suit…”
Mandigo v. Mandigo, 266 A.2d 434 (Vt. 1970). · cites it 3× “Attention might well be called to the fact that since this case was heard and disposed of below, the policy of the State with regard to the cause of a divorce under 15 V.S.A. Section 551, sub-section 7 was changed by the adjourned session of the 1969 Legislature.”
Show all 34 citing cases →
— Vt. Stat. Ann. tit. 15, § 551(3) — 1 case
Winslow v. Winslow, 251 A.2d 419 (Vt. 1969).
— Vt. Stat. Ann. tit. 15, § 551(4) — 1 case
Emmons v. Emmons, 450 A.2d 1113 (Vt. 1982). “15 V.S.A. § 551(4). It seems likely, therefore, that the trial court employed "abandoned" in its broader, generic sense, that is, to forsake, leave, or desert, "as a person to whom one owes [a] duty.”
— Vt. Stat. Ann. tit. 15, § 551(7) — 27 cases
Emmons v. Emmons, 450 A.2d 1113 (Vt. 1982). “15 V.S.A. § 551(4). It seems likely, therefore, that the trial court employed "abandoned" in its broader, generic sense, that is, to forsake, leave, or desert, "as a person to whom one owes [a] duty.”
Nickerson v. Nickerson, 605 A.2d 1331 (Vt. 1992). “Nevertheless, mere physical custody by one of two fit parents, during the time the estranged spouses live "apart" to satisfy the no-fault divorce requirements, should not in itself cause a former primary-care-provider to lose that status.”
LeBlanc v. LeBlanc, 2014 VT 65 (Vt. 2014). “See 15 V.S.A. § 551(7). ¶ 17. Mother moved for reconsideration, challenging the court’s custody award and its visitation schedule.”
Conley v. Crisafulli, 2010 VT 38 (Vt. 2010). “See 15 V.S.A. § 551(7) (stating that divorce may be granted “[w]hen a married person has lived apart from his or her spouse for six consecutive months and the court finds that the resumption of marital relations is not reasonably probable”).”
Scott v. Scott, 586 A.2d 1140 (Vt. 1990). “Plaintiff had initially filed for divorce by alleging an anticipatory separation, meaning that by the time of the final hearing the six-month living apart period required by 15 V.S.A. § 551(7) would have occurred. At the hearing on the motion to expedite, plaintiff represented…”
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