Vermont Statutes Annotated

Vt. Stat. Ann. tit. 19, § 310 (2026)

✓ current as of May 2026
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(Cite as: 19 V.S.A. § 310)
Notes of Decisions
Cited in 16 cases (3 in the last 5 years), 1991–2026 · leading case: Sagar v. Warren Selectboard, 744 A.2d 422 (Vt. 1999).
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Sagar v. Warren Selectboard, 744 A.2d 422 (Vt. 1999). · cites it 8× “Nor is the majority's decision supported by its examination of the history of 19 V.S.A. § 310, the statute requiring towns to keep roads in good repair during all seasons.”
Town of Calais v. Cnty. Road Commissioners, 795 A.2d 1267 (Vt. 2002). · cites it 3× “The trial court held that the Town had not fulfilled its statutory responsibility to promote the public good, necessity, and convenience under 19 V.S.A. § 310(b), which provides: Class 4 highways may be maintained to the extent required by the necessity of the town, the public…”
In Re Town High. No. 20, 2012 VT 17 (Vt. 2012). · cites it 2× “Hansen relied in this regard on 19 V.S.A. § 310(b), which provides that "Class 4 highways may be maintained to the extent required by the necessity of the town, the public good and the convenience of the inhabitants of the town, or may be reclassified using the same procedures…”
Demarest v. Town of Underhill, 87 A.3d 439 (Vt. 2013). · cites it 4× “§ 310(b), which provides that “Class 4 highways may be maintained to the extent required by the necessity of the town, the public good and the convenience of the inhabitants of the town, or may be reclassified using the same procedures as for laying out highways and meeting the…”
Ketchum v. Town of Dorset, 2011 VT 49 (Vt. 2011). “Furthermore, Hansen is distinguishable because the statute specifically explains that reclassification of a class 4 highway is to be done “using the same procedures as for laying out highways,” 19 V.S.A. § 310(b), and the decision relied on this language.”
David Demarest v. Town of Underhill, 2016 VT 10 (Vt. 2016). · cites it 2× “Specifically, the Town raises two arguments: (1) that the trial court erred in its interpretation of 19 V.S.A. § 310(b) by failing to recognize that § 310(b) allows for discretion in determining whether to maintain and repair Class 4 highways as long as that discretion is not…”
McMurphy v. State, 757 A.2d 1043 (Vt. 2000). “§ 931, recodified at 19 V.S.A. § 310(a) (“A town shall keep its .”
Holly Bartlett v. John Roberts & LaLauni Rawls, 2020 VT 24 (Vt. 2020). “) (holding town has discretion whether to maintain and repair class 4 highways); 19 V.S.A. § 310(b)-(c) (providing town “may” maintain class 4 roads and is not obligated to maintain legal trails).”
Smith v. Town of Derby, 742 A.2d 757 (Vt. 1999). · cites it 2× “" 19 V.S.A. § 310(b). Here, neither necessity nor public good support maintaining a bridge for the sole use of the owners of one parcel of land and their invitees.”
Hansen v. Town of Charleston, 597 A.2d 321 (Vt. 1991). “The trial court’s jurisdiction is based primarily on 19 V.S.A. § 310(b), which provides that reclassification is subject to the “same procedures as for laying out highways.”
Demarest & Moulton v. Town of Underhill, 195 Vt. 204 (Vt. 2013). · cites it 4× “In that footnote, we cited to 19 V.S.A. § 310(b), which provides that “Class 4 highways may be maintained to the extent required by the necessity of the town, the public good and the convenience of the inhabitants of the town, or may be reclassified using the same procedures as…”
Escheverria v. Tunbridge (Vt. Super. Ct. 2025). · cites it 7× “* * * * 19 V.S.A. § 310. Highways, bridges, and trails (a) A town shall keep its class 1, 2, and 3 highways and bridges in good and sufficient repair during all seasons of the year, except that based on safety considerations for the traveling public and municipal employees, the…”
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— Vt. Stat. Ann. tit. 19, § 310(a) — 3 cases
Sagar v. Warren Selectboard, 744 A.2d 422 (Vt. 1999). “Nor is the majority's decision supported by its examination of the history of 19 V.S.A. § 310, the statute requiring towns to keep roads in good repair during all seasons.”
McMurphy v. State, 757 A.2d 1043 (Vt. 2000). “§ 931, recodified at 19 V.S.A. § 310(a) (“A town shall keep its .”
Krull v. Town of Huntington (Vt. Super. Ct. 2017).
— Vt. Stat. Ann. tit. 19, § 310(b) — 12 cases
In Re Town High. No. 20, 2012 VT 17 (Vt. 2012). “Hansen relied in this regard on 19 V.S.A. § 310(b), which provides that "Class 4 highways may be maintained to the extent required by the necessity of the town, the public good and the convenience of the inhabitants of the town, or may be reclassified using the same procedures…”
Town of Calais v. Cnty. Road Commissioners, 795 A.2d 1267 (Vt. 2002). “The trial court held that the Town had not fulfilled its statutory responsibility to promote the public good, necessity, and convenience under 19 V.S.A. § 310(b), which provides: Class 4 highways may be maintained to the extent required by the necessity of the town, the public…”
Demarest v. Town of Underhill, 87 A.3d 439 (Vt. 2013). “§ 310(b), which provides that “Class 4 highways may be maintained to the extent required by the necessity of the town, the public good and the convenience of the inhabitants of the town, or may be reclassified using the same procedures as for laying out highways and meeting the…”
Ketchum v. Town of Dorset, 2011 VT 49 (Vt. 2011). “Furthermore, Hansen is distinguishable because the statute specifically explains that reclassification of a class 4 highway is to be done “using the same procedures as for laying out highways,” 19 V.S.A. § 310(b), and the decision relied on this language.”
David Demarest v. Town of Underhill, 2016 VT 10 (Vt. 2016). “Specifically, the Town raises two arguments: (1) that the trial court erred in its interpretation of 19 V.S.A. § 310(b) by failing to recognize that § 310(b) allows for discretion in determining whether to maintain and repair Class 4 highways as long as that discretion is not…”
— Vt. Stat. Ann. tit. 19, § 310(c) — 3 cases
Demarest v. Town of Underhill, 87 A.3d 439 (Vt. 2013). “§ 310(b), which provides that “Class 4 highways may be maintained to the extent required by the necessity of the town, the public good and the convenience of the inhabitants of the town, or may be reclassified using the same procedures as for laying out highways and meeting the…”
Demarest & Moulton v. Town of Underhill, 195 Vt. 204 (Vt. 2013). “In that footnote, we cited to 19 V.S.A. § 310(b), which provides that “Class 4 highways may be maintained to the extent required by the necessity of the town, the public good and the convenience of the inhabitants of the town, or may be reclassified using the same procedures as…”
Escheverria v. Tunbridge (Vt. Super. Ct. 2025). “* * * * 19 V.S.A. § 310. Highways, bridges, and trails (a) A town shall keep its class 1, 2, and 3 highways and bridges in good and sufficient repair during all seasons of the year, except that based on safety considerations for the traveling public and municipal employees, the…”
— Vt. Stat. Ann. tit. 19, § 310(e) — 1 case
Town of Calais v. Cnty. Road Commissioners, 795 A.2d 1267 (Vt. 2002). “The trial court held that the Town had not fulfilled its statutory responsibility to promote the public good, necessity, and convenience under 19 V.S.A. § 310(b), which provides: Class 4 highways may be maintained to the extent required by the necessity of the town, the public…”
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