Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 752 (2026)

✓ current as of May 2026
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Subchapter 006 : PROPERTY SETTLEMENT; MAINTENANCE

(Cite as: 15 V.S.A. § 752)
Notes of Decisions
Cited in 105 cases (15 in the last 5 years), 1983–2026 · leading case: Justis v. Rist, 617 A.2d 148 (Vt. 1992).
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Justis v. Rist, 617 A.2d 148 (Vt. 1992). · cites it 18× “Vermont's maintenance statute, 15 V.S.A. § 752, authorizes the trial court to order either spouse to make rehabilitative or permanent maintenance payments if the other spouse lacks sufficient income to meet reasonable needs and is unable to maintain the standard of living…”
Klein v. Klein, 555 A.2d 382 (Vt. 1988). · cites it 8× “The relevant statute, 15 V.S.A. § 752(a), authorizes an award of maintenance either rehabilitative or permanent in character if the spouse seeking maintenance: “(1) lacks sufficient income, property, or both .”
Kohut v. Kohut, 663 A.2d 942 (Vt. 1995). · cites it 14× “We too believe that financial dependence upon the state demonstrated an obvious lack of personal income, property, or both, thereby justifying a maintenance award under 15 V.S.A. § 752(a). We cannot fault the court for not fashioning a maintenance award based on the exact…”
Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). · cites it 6× “Moreover, the court did not award Ellen a "share" of the marital estate; it calculated a cash award that it considered appropriate given the relevant statutory factors.”
Kasser v. Kasser, 2006 VT 2 (Vt. 2006). · cites it 8× “Based on numerous findings, the court concluded that, in light of its distribution of the marital estate, including the $712,000 awarded to wife ($345,000 in cash; $300,000 payable over ten years at 6% interest; her IRA worth $27,000; and a $40,000 car), and considering the…”
Nicola Weaver v. David Weaver, 171 A.3d 374 (Vt. 2017). · cites it 7× “Specifically, on remand the court must make a finding to determine how much of the award was compensatory in order to clarify whether the permanent award, including its compensatory aspect, is subject to modification under the appropriate change of circumstances considerations…”
Molleur v. Molleur, 2012 VT 16 (Vt. 2012). · cites it 6× “15 V.S.A. § 752(a). The court is authorized to award maintenance in an amount and for a time as "the court deems just" after considering all relevant factors, including the recipient party's financial resources and ability to meet his or her needs independently, the time and…”
Gulian v. Gulian, 790 A.2d 1116 (Vt. 2001). · cites it 10× “In its findings, the court accepted mother's report that her expenses, excluding costs for the children, were approximately $3000 per month.”
Bell v. Bell, 643 A.2d 846 (Vt. 1994). · cites it 6× “2d 148, 150 (1992), that 15 V.S.A. § 752 does not reflect legislative intent to override the long-established rule that the obligation to pay maintenance ceases upon the death of either party.”
Boisselle v. Boisselle, 648 A.2d 388 (Vt. 1994). · cites it 6× “The issue of maintenance is governed by 15 V.S.A. § 752, which gives the family court discretion to award maintenance from one spouse to the other upon a showing of certain criteria.”
Chaker v. Chaker, 581 A.2d 737 (Vt. 1990). · cites it 4× “The relevant statute allows an award of maintenance, either rehabilitative or permanent, to a spouse where the court finds: (1) the spouse lacks sufficient income and/or property to “provide for his or her reasonable needs” and (2) the spouse is unable to support himself or…”
Quesnel v. Quesnel, 549 A.2d 644 (Vt. 1988). · cites it 4× “Under the provisions of 15 V.S.A. § 752(a), a court may properly order maintenance payments if it finds that the spouse seeking maintenance lacks sufficient assets and income to "provide for his or her reasonable needs," and "is unable to support himself or herself through…”
Show all 105 citing cases →
— Vt. Stat. Ann. tit. 15, § 752(a) — 52 cases
Kohut v. Kohut, 663 A.2d 942 (Vt. 1995). “We too believe that financial dependence upon the state demonstrated an obvious lack of personal income, property, or both, thereby justifying a maintenance award under 15 V.S.A. § 752(a). We cannot fault the court for not fashioning a maintenance award based on the exact…”
Molleur v. Molleur, 2012 VT 16 (Vt. 2012). “15 V.S.A. § 752(a). The court is authorized to award maintenance in an amount and for a time as "the court deems just" after considering all relevant factors, including the recipient party's financial resources and ability to meet his or her needs independently, the time and…”
Justis v. Rist, 617 A.2d 148 (Vt. 1992). “Vermont's maintenance statute, 15 V.S.A. § 752, authorizes the trial court to order either spouse to make rehabilitative or permanent maintenance payments if the other spouse lacks sufficient income to meet reasonable needs and is unable to maintain the standard of living…”
Kasser v. Kasser, 2006 VT 2 (Vt. 2006). “Based on numerous findings, the court concluded that, in light of its distribution of the marital estate, including the $712,000 awarded to wife ($345,000 in cash; $300,000 payable over ten years at 6% interest; her IRA worth $27,000; and a $40,000 car), and considering the…”
Gulian v. Gulian, 790 A.2d 1116 (Vt. 2001). “In its findings, the court accepted mother's report that her expenses, excluding costs for the children, were approximately $3000 per month.”
— Vt. Stat. Ann. tit. 15, § 752(a)(1) — 21 cases
Cabot v. Cabot, 697 A.2d 644 (Vt. 1997). “Moreover, the court did not award Ellen a "share" of the marital estate; it calculated a cash award that it considered appropriate given the relevant statutory factors.”
Quesnel v. Quesnel, 549 A.2d 644 (Vt. 1988). “Under the provisions of 15 V.S.A. § 752(a), a court may properly order maintenance payments if it finds that the spouse seeking maintenance lacks sufficient assets and income to "provide for his or her reasonable needs," and "is unable to support himself or herself through…”
Kohut v. Kohut, 663 A.2d 942 (Vt. 1995). “We too believe that financial dependence upon the state demonstrated an obvious lack of personal income, property, or both, thereby justifying a maintenance award under 15 V.S.A. § 752(a). We cannot fault the court for not fashioning a maintenance award based on the exact…”
DeLeonardis v. Page, 2010 VT 52 (Vt. 2010).
Klein v. Klein, 555 A.2d 382 (Vt. 1988). “The relevant statute, 15 V.S.A. § 752(a), authorizes an award of maintenance either rehabilitative or permanent in character if the spouse seeking maintenance: “(1) lacks sufficient income, property, or both .”
— Vt. Stat. Ann. tit. 15, § 752(a)(2) — 4 cases
Klein v. Klein, 555 A.2d 382 (Vt. 1988). “The relevant statute, 15 V.S.A. § 752(a), authorizes an award of maintenance either rehabilitative or permanent in character if the spouse seeking maintenance: “(1) lacks sufficient income, property, or both .”
Gulian v. Gulian, 790 A.2d 1116 (Vt. 2001). “In its findings, the court accepted mother's report that her expenses, excluding costs for the children, were approximately $3000 per month.”
Rayburn Reed v. Melissa Reed (Vt. 2026).
May Chiles (May Mantell) v. John Vaughan Chiles (Vt. 2015).
— Vt. Stat. Ann. tit. 15, § 752(b) — 38 cases
Kohut v. Kohut, 663 A.2d 942 (Vt. 1995). “We too believe that financial dependence upon the state demonstrated an obvious lack of personal income, property, or both, thereby justifying a maintenance award under 15 V.S.A. § 752(a). We cannot fault the court for not fashioning a maintenance award based on the exact…”
Nicola Weaver v. David Weaver, 171 A.3d 374 (Vt. 2017). “Specifically, on remand the court must make a finding to determine how much of the award was compensatory in order to clarify whether the permanent award, including its compensatory aspect, is subject to modification under the appropriate change of circumstances considerations…”
Kasser v. Kasser, 2006 VT 2 (Vt. 2006). “Based on numerous findings, the court concluded that, in light of its distribution of the marital estate, including the $712,000 awarded to wife ($345,000 in cash; $300,000 payable over ten years at 6% interest; her IRA worth $27,000; and a $40,000 car), and considering the…”
Cleverly v. Cleverly, 513 A.2d 612 (Vt. 1986).
Justis v. Rist, 617 A.2d 148 (Vt. 1992). “Vermont's maintenance statute, 15 V.S.A. § 752, authorizes the trial court to order either spouse to make rehabilitative or permanent maintenance payments if the other spouse lacks sufficient income to meet reasonable needs and is unable to maintain the standard of living…”
— Vt. Stat. Ann. tit. 15, § 752(b)(1) — 17 cases
Klein v. Klein, 555 A.2d 382 (Vt. 1988). “The relevant statute, 15 V.S.A. § 752(a), authorizes an award of maintenance either rehabilitative or permanent in character if the spouse seeking maintenance: “(1) lacks sufficient income, property, or both .”
Justis v. Rist, 617 A.2d 148 (Vt. 1992). “Vermont's maintenance statute, 15 V.S.A. § 752, authorizes the trial court to order either spouse to make rehabilitative or permanent maintenance payments if the other spouse lacks sufficient income to meet reasonable needs and is unable to maintain the standard of living…”
Gulian v. Gulian, 790 A.2d 1116 (Vt. 2001). “In its findings, the court accepted mother's report that her expenses, excluding costs for the children, were approximately $3000 per month.”
Osborn v. Osborn, 519 A.2d 1161 (Vt. 1986).
Braun v. Greenblatt, 2007 VT 53 (Vt. 2007).
— Vt. Stat. Ann. tit. 15, § 752(b)(3) — 6 cases
Bell v. Bell, 643 A.2d 846 (Vt. 1994). “2d 148, 150 (1992), that 15 V.S.A. § 752 does not reflect legislative intent to override the long-established rule that the obligation to pay maintenance ceases upon the death of either party.”
Kohut v. Kohut, 663 A.2d 942 (Vt. 1995). “We too believe that financial dependence upon the state demonstrated an obvious lack of personal income, property, or both, thereby justifying a maintenance award under 15 V.S.A. § 752(a). We cannot fault the court for not fashioning a maintenance award based on the exact…”
Klein v. Klein, 555 A.2d 382 (Vt. 1988). “The relevant statute, 15 V.S.A. § 752(a), authorizes an award of maintenance either rehabilitative or permanent in character if the spouse seeking maintenance: “(1) lacks sufficient income, property, or both .”
Justis v. Rist, 617 A.2d 148 (Vt. 1992). “Vermont's maintenance statute, 15 V.S.A. § 752, authorizes the trial court to order either spouse to make rehabilitative or permanent maintenance payments if the other spouse lacks sufficient income to meet reasonable needs and is unable to maintain the standard of living…”
Clapp v. Clapp, 653 A.2d 72 (Vt. 1994).
— Vt. Stat. Ann. tit. 15, § 752(b)(4) — 2 cases
Klein v. Klein, 555 A.2d 382 (Vt. 1988). “The relevant statute, 15 V.S.A. § 752(a), authorizes an award of maintenance either rehabilitative or permanent in character if the spouse seeking maintenance: “(1) lacks sufficient income, property, or both .”
Amanda Houle v. Jason Houle (Vt. 2023).
— Vt. Stat. Ann. tit. 15, § 752(b)(5) — 4 cases
Chaker v. Chaker, 581 A.2d 737 (Vt. 1990). “The relevant statute allows an award of maintenance, either rehabilitative or permanent, to a spouse where the court finds: (1) the spouse lacks sufficient income and/or property to “provide for his or her reasonable needs” and (2) the spouse is unable to support himself or…”
Naumann v. Kurz, 566 A.2d 1342 (Vt. 1989).
Amanda Houle v. Jason Houle (Vt. 2023).
Victor Calhoun v. Dawn Calhoun (Vt. 2012).
— Vt. Stat. Ann. tit. 15, § 752(b)(6) — 7 cases
Klein v. Klein, 555 A.2d 382 (Vt. 1988). “The relevant statute, 15 V.S.A. § 752(a), authorizes an award of maintenance either rehabilitative or permanent in character if the spouse seeking maintenance: “(1) lacks sufficient income, property, or both .”
Golden v. Cooper-Ellis, 181 Vt. 359 (Vt. 2007).
Nicola Weaver v. David Weaver, 171 A.3d 374 (Vt. 2017). “Specifically, on remand the court must make a finding to determine how much of the award was compensatory in order to clarify whether the permanent award, including its compensatory aspect, is subject to modification under the appropriate change of circumstances considerations…”
Golden v. Cooper-Ellis, 2007 VT 15 (Vt. 2007).
DeGrace v. DeGrace, 520 A.2d 987 (Vt. 1986).
— Vt. Stat. Ann. tit. 15, § 752(b)(7) — 4 cases
Molleur v. Molleur, 2012 VT 16 (Vt. 2012). “15 V.S.A. § 752(a). The court is authorized to award maintenance in an amount and for a time as "the court deems just" after considering all relevant factors, including the recipient party's financial resources and ability to meet his or her needs independently, the time and…”
Bell v. Bell, 643 A.2d 846 (Vt. 1994). “2d 148, 150 (1992), that 15 V.S.A. § 752 does not reflect legislative intent to override the long-established rule that the obligation to pay maintenance ceases upon the death of either party.”
Chaker v. Chaker, 581 A.2d 737 (Vt. 1990). “The relevant statute allows an award of maintenance, either rehabilitative or permanent, to a spouse where the court finds: (1) the spouse lacks sufficient income and/or property to “provide for his or her reasonable needs” and (2) the spouse is unable to support himself or…”
David de Grasse v. Renee de Grasse (Vt. 2011).
— Vt. Stat. Ann. tit. 15, § 752(b)(8) — 1 case
Donna M. Jaro v. Todd M. Jaro, 198 A.3d 1270 (Vt. 2018).
— Vt. Stat. Ann. tit. 15, § 752(b)(9) — 2 cases
Amanda Houle v. Jason Houle (Vt. 2023).
Mary Ann Johnson-Condon v. Michael Condon (Vt. 2026).
— Vt. Stat. Ann. tit. 15, § 752(b)(l) — 1 case
Justis v. Rist, 617 A.2d 148 (Vt. 1992). “Vermont's maintenance statute, 15 V.S.A. § 752, authorizes the trial court to order either spouse to make rehabilitative or permanent maintenance payments if the other spouse lacks sufficient income to meet reasonable needs and is unable to maintain the standard of living…”
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