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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 941 (2026)

✓ current as of May 2026
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Subchapter 005 : INSURANCE AGAINST UNINSURED, UNDERINSURED, OR UNKNOWN MOTORISTS

(Cite as: 23 V.S.A. § 941)
Notes of Decisions
Cited in 64 cases (7 in the last 5 years), 1973–2024 · leading case: Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009).
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Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009). · cites it 29× “We agreed to review the following question certified from the United States District Court for the District of Vermont: "Whether Vermont's uninsured/underinsured motorist statute, 23 V.”
Progressive Casuality Ins. Co. v. MMG Insurnace Co., 2014 VT 70 (Vt. 2014). · cites it 16× “23 V.S.A. § 941(a). In light of this requirement, the enforceability of the “owned-vehicle” and “covered-vehicle” exclusions turns on our understanding of the statutory definition of “underinsured motor vehicle.”
Sanders v. St. Paul Mercury Ins., 536 A.2d 914 (Vt. 1987). · cites it 7× “Plaintiff advances all of the foregoing theories of recovery, arguing that Part C of the policy is ambiguous and that the ambi *500 guity should be resolved in favor of the insured; that reading the policy language to prevent stacking would be inconsistent with 23 V.S.A. § 941…”
Colwell v. Allstate Ins., 2003 VT 5 (Vt. 2003). · cites it 3× “The common issue presented by these two consolidated appeals is whether a tortfeasor-motorist is underinsured *63 within the meaning of 23 V.S.A. § 941(f) where the tortfeasor’s liability policy limits are greater than the injured party’s underinsurance limits, but are…”
Brunet v. Am. Ins., 660 F. Supp. 843 (D. Vt. 1987). · cites it 10× “§ 941(c)? The Vermont Uninsured Motorist statute, 23 V.S.A. § 941, was amended as of July 1, 1983, to require that UM coverage “for new or renewed policies .”
Progressive Ins. v. Brown Ex Rel. Brown, 2008 VT 103 (Vt. 2008). · cites it 3× “In its ruling, the court concluded that the policy definition of “uninsured motor vehicle,” which excludes any vehicle owned by the insured or a relative, is unenforceable because it violates the public policy expressed in Vermont’s UM statute, 23 V.S.A. § 941(a). On appeal,…”
Marian R. Canedy v. Liberty Mut. Ins. Co., 126 F.3d 100 (2d Cir. 1997). · cites it 2× “23 V.S.A. § 941(a). As its text suggests, this statute requires every liability policy delivered or issued for delivery in Vermont to include UIM coverage for the protection of the “persons insured” under such liability policy.”
State v. Morse, 2014 VT 84 (Vt. 2014). · cites it 4× “23 V.S.A. § 941(a). Any reluctance she may have had to make use of her own insurance coverage is irrelevant.”
Muir v. Hartford Accident & Indem. Co., 522 A.2d 236 (Vt. 1987). · cites it 4× “The remedial purpose of 23 V.S.A. § 941, Goodrich v. Lumbermens Mutual Casualty Co.”
Goodrich v. Lumbermens Mut. Cas. Co., 423 F. Supp. 838 (D. Vt. 1976). · cites it 6× “See 23 V.S.A. §§ 941 and 801. For the *840 purposes of this motion, the parties have stipulated that the plaintiff’s damages may exceed $10,000.”
Bradley v. H.A. Manosh Corp., 601 A.2d 978 (Vt. 1991). · cites it 3× “” 23 V.S.A. § 941(a) (emphasis added). In other words, UM insurance payments compensate accident victims for damages caused by uninsured motorists who are found or are conceded to have been negligent.”
Rotman v. Progressive Ins., 955 F. Supp. 2d 272 (D. Vt. 2013). · cites it 2× “As a threshold issue, Defendants correctly observe that the Vermont Supreme Court has not affirmatively recognized a “miss and run” cause of action under Vermont’s uninsured/underinsured (“UIM”) motorist statute, 23 V.S.A. § 941. The Vermont trial courts, however, have held that…”
Show all 64 citing cases →
— Vt. Stat. Ann. tit. 23, § 941(a) — 27 cases
Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009). “We agreed to review the following question certified from the United States District Court for the District of Vermont: "Whether Vermont's uninsured/underinsured motorist statute, 23 V.”
Progressive Ins. v. Brown Ex Rel. Brown, 2008 VT 103 (Vt. 2008). “In its ruling, the court concluded that the policy definition of “uninsured motor vehicle,” which excludes any vehicle owned by the insured or a relative, is unenforceable because it violates the public policy expressed in Vermont’s UM statute, 23 V.S.A. § 941(a). On appeal,…”
Marian R. Canedy v. Liberty Mut. Ins. Co., 126 F.3d 100 (2d Cir. 1997). “23 V.S.A. § 941(a). As its text suggests, this statute requires every liability policy delivered or issued for delivery in Vermont to include UIM coverage for the protection of the “persons insured” under such liability policy.”
State v. Morse, 2014 VT 84 (Vt. 2014). “23 V.S.A. § 941(a). Any reluctance she may have had to make use of her own insurance coverage is irrelevant.”
Sanders v. St. Paul Mercury Ins., 536 A.2d 914 (Vt. 1987). “Plaintiff advances all of the foregoing theories of recovery, arguing that Part C of the policy is ambiguous and that the ambi *500 guity should be resolved in favor of the insured; that reading the policy language to prevent stacking would be inconsistent with 23 V.S.A. § 941…”
— Vt. Stat. Ann. tit. 23, § 941(b) — 2 cases
Coop. Fire Ins. v. Gray, 599 A.2d 360 (Vt. 1991).
Co-op Fire Ins. Ass'n of Vermont v. Gray, 599 A.2d 360 (Vt. 1991).
— Vt. Stat. Ann. tit. 23, § 941(c) — 7 cases
Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009). “We agreed to review the following question certified from the United States District Court for the District of Vermont: "Whether Vermont's uninsured/underinsured motorist statute, 23 V.”
Brunet v. Am. Ins., 660 F. Supp. 843 (D. Vt. 1987). “§ 941(c)? The Vermont Uninsured Motorist statute, 23 V.S.A. § 941, was amended as of July 1, 1983, to require that UM coverage “for new or renewed policies .”
Merkel v. Nationwide Ins., 693 A.2d 706 (Vt. 1997).
Lecours v. Nationwide Mut. Ins., 657 A.2d 177 (Vt. 1995).
Rhault v. Tsagarakos, 361 F. Supp. 202 (D. Vt. 1973).
— Vt. Stat. Ann. tit. 23, § 941(e) — 16 cases
Bradley v. H.A. Manosh Corp., 601 A.2d 978 (Vt. 1991). “” 23 V.S.A. § 941(a) (emphasis added). In other words, UM insurance payments compensate accident victims for damages caused by uninsured motorists who are found or are conceded to have been negligent.”
Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009). “We agreed to review the following question certified from the United States District Court for the District of Vermont: "Whether Vermont's uninsured/underinsured motorist statute, 23 V.”
Brunet v. Am. Ins., 660 F. Supp. 843 (D. Vt. 1987). “§ 941(c)? The Vermont Uninsured Motorist statute, 23 V.S.A. § 941, was amended as of July 1, 1983, to require that UM coverage “for new or renewed policies .”
Muir v. Hartford Accident & Indem. Co., 522 A.2d 236 (Vt. 1987). “The remedial purpose of 23 V.S.A. § 941, Goodrich v. Lumbermens Mutual Casualty Co.”
Webb v. United States Fid. & Guar. Co., 605 A.2d 1344 (Vt. 1992).
— Vt. Stat. Ann. tit. 23, § 941(f) — 16 cases
Colwell v. Allstate Ins., 2003 VT 5 (Vt. 2003). “The common issue presented by these two consolidated appeals is whether a tortfeasor-motorist is underinsured *63 within the meaning of 23 V.S.A. § 941(f) where the tortfeasor’s liability policy limits are greater than the injured party’s underinsurance limits, but are…”
Progressive Casuality Ins. Co. v. MMG Insurnace Co., 2014 VT 70 (Vt. 2014). “23 V.S.A. § 941(a). In light of this requirement, the enforceability of the “owned-vehicle” and “covered-vehicle” exclusions turns on our understanding of the statutory definition of “underinsured motor vehicle.”
Webb v. United States Fid. & Guar. Co., 605 A.2d 1344 (Vt. 1992).
Brunet v. Am. Ins., 660 F. Supp. 843 (D. Vt. 1987). “§ 941(c)? The Vermont Uninsured Motorist statute, 23 V.S.A. § 941, was amended as of July 1, 1983, to require that UM coverage “for new or renewed policies .”
McGoff v. Acadia Ins., 2011 VT 102 (Vt. 2011).
— Vt. Stat. Ann. tit. 23, § 941(f)(2) — 1 case
Progressive Casuality Ins. Co. v. MMG Insurnace Co., 2014 VT 70 (Vt. 2014). “23 V.S.A. § 941(a). In light of this requirement, the enforceability of the “owned-vehicle” and “covered-vehicle” exclusions turns on our understanding of the statutory definition of “underinsured motor vehicle.”
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