Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 554 (2026)

✓ current as of May 2026
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Subchapter 002 : DIVORCE

(Cite as: 15 V.S.A. § 554)
Notes of Decisions
Cited in 17 cases (3 in the last 5 years), 1982–2024 · leading case: Est. of Ladd v. Est. of Ladd, 640 A.2d 29 (Vt. 1994).
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Est. of Ladd v. Est. of Ladd, 640 A.2d 29 (Vt. 1994). · cites it 4× “15 V.S.A. § 554(b) (effective June 4, 1990).”
Gazo v. Gazo, 697 A.2d 342 (Vt. 1997). · cites it 2× “See 15 V.S.A. § 554(b). Where, as here, there was no reason given why the evidence could not have been presented at trial, the court did not abuse its discretion in refusing to reopen.”
Russell v. Russell, 597 A.2d 798 (Vt. 1991). · cites it 2× “60(b)(2) and 15 V.S.A. § 554. This motion alleged that the wife had quit her job due to a worsening diabetic condi *298 tion and needed more maintenance.”
Jones v. Murphy, 772 A.2d 502 (Vt. 2001). · cites it 2× “15 V.S.A. § 554. The nisi period for the Jones's divorce order expired in November 1998.”
Caroline Maier v. Siegfried Maier, 2021 VT 88 (Vt. 2021). · cites it 2× “In addition, we note that subsequent to our decision in Ladd the Legislature amended 15 VS.A. § 554 to provide that “[i]f one of the parties dies prior to the expiration of the nisi period, the decree shall be deemed absolute immediately prior to the death.”
Richwagen v. Richwagen, 539 A.2d 540 (Vt. 1987). · cites it 2× “2 15 V.S.A. § 554 was formerly set out as § 553.”
Richwagen v. Richwagen, 568 A.2d 419 (Vt. 1989). “On December 15, 1987, this Court reversed the decision of the superior court, holding that the trial court did not have authority to vacate the first divorce order and reopen the evidence because the expiration of the nisi period had divested the trial court of jurisdiction…”
O'Connell-Starkey v. Starkey, 2007 VT 128 (Vt. 2007). “15 V.S.A. § 554. See also In re M.Z., 472 N.”
Richard v. Richard, 2014 VT 58 (Vt. 2014). “See 15 V.S.A. § 554(b) (stating that a divorce decree is a civil judgment under the civil rules); V.”
Angela Blake v. Damon Petrie, 2020 VT 92 (Vt. 2020). “See 15 V.S.A. § 554(b) (“A decree of divorce shall constitute a civil judgment under the Vermont Rules of Civil Procedure.”
Slansky v. Slansky, 556 A.2d 94 (Vt. 1988). “On September 2, 1986, defendant moved pursuant to V.R.C.P. 60(b) for relief from judgment because he believed “that the stipulation he executed on February 10, 1986, was not the product of consent freely and voluntarily given .”
Downs v. Downs, 549 A.2d 1382 (Vt. 1988). “15 V.S.A. § 554(b) provides in pertinent part that, “at any time before the decree becomes absolute .”
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— Vt. Stat. Ann. tit. 15, § 554(a) — 3 cases
Caroline Maier v. Siegfried Maier, 2021 VT 88 (Vt. 2021). “In addition, we note that subsequent to our decision in Ladd the Legislature amended 15 VS.A. § 554 to provide that “[i]f one of the parties dies prior to the expiration of the nisi period, the decree shall be deemed absolute immediately prior to the death.”
John P. Maille v. Kathleen Kirkpatrick (Maille) (Vt. 2023).
Darlene Seely v. Robert Paluba (Vt. 2024).
— Vt. Stat. Ann. tit. 15, § 554(b) — 8 cases
Est. of Ladd v. Est. of Ladd, 640 A.2d 29 (Vt. 1994). “15 V.S.A. § 554(b) (effective June 4, 1990).”
Gazo v. Gazo, 697 A.2d 342 (Vt. 1997). “See 15 V.S.A. § 554(b). Where, as here, there was no reason given why the evidence could not have been presented at trial, the court did not abuse its discretion in refusing to reopen.”
Richwagen v. Richwagen, 568 A.2d 419 (Vt. 1989). “On December 15, 1987, this Court reversed the decision of the superior court, holding that the trial court did not have authority to vacate the first divorce order and reopen the evidence because the expiration of the nisi period had divested the trial court of jurisdiction…”
Richard v. Richard, 2014 VT 58 (Vt. 2014). “See 15 V.S.A. § 554(b) (stating that a divorce decree is a civil judgment under the civil rules); V.”
Richwagen v. Richwagen, 539 A.2d 540 (Vt. 1987). “2 15 V.S.A. § 554 was formerly set out as § 553.”
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