Vt. Stat. Ann. » Title 24 Chapter 55
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 24, § 1931 (2026)

✓ current as of May 2026
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(Cite as: 24 V.S.A. § 1931)
Notes of Decisions
Cited in 17 cases (3 in the last 5 years), 1975–2025 · leading case: Adam Hubacz v. The Vill. of Waterbury, 187 A.3d 367 (Vt. 2018).
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Adam Hubacz v. The Vill. of Waterbury, 187 A.3d 367 (Vt. 2018). · cites it 9× “The superior court certified the following question to this Court: Is a State's Attorney's unilateral decision to refuse to prosecute any cases investigated by a particular municipal police officer, alone, a sufficient basis for termination of the officer pursuant to 24 V.S.A. §…”
Nelson v. Town of St. Johnsbury, LaMotte, Oddy, Ruggles, Rust, Timson & Town of St. Johnsbury, 2015 VT 5 (Vt. 2015). · cites it 2× “3d 1246 (recognizing that 24 V.S.A. § 1931(a), which states that officers “shall hold office during good behavior, unless sooner removed for cause,” authorizes town to remove police chief only for cause).”
Turnley v. Town of Vernon, 2013 VT 42 (Vt. 2013). · cites it 2× “” 24 V.S.A. § 1931(a). The appointing authority may schedule a hearing to consider charges “[w]henever it appears to the appointing authority .”
Franklin Cnty. Sheriff's Off. v. St. Albans City Police Dep't, 2012 VT 62 (Vt. 2012). “§ 1936a (constable law enforcement authority); 24 V.S.A. §§ 1931, 1935 (municipal police departments); 24 V.”
Burwell v. Peyton, 131 F. Supp. 3d 268 (D. Vt. 2015). “]” 24 V.S.A. § 1931(a), (b). The state statutes governing municipal police officers and police chiefs thus impose only duties “owed to the community as a whole.”
White River Amusement Pub. v. Town of Hartford, Vt., 412 F. Supp. 2d 416 (D. Vt. 2005). “§§ 1235-38 (town manager); 24 V.S.A. § 1931(b) (municipal police chief).”
Hee v. Everlof, 812 F. Supp. 1350 (D. Vt. 1993). “§ 901 (1975) (An action against an appointed municipal officer must be brought against the municipality); 24 V.S.A. § 1931(a) (1975) (police officers are appointed municipal officers).”
Wyatt v. City of Barre, 885 F. Supp. 2d 682 (D. Vt. 2012). · cites it 2× “In Hee , this Court looked to the text of Vt. Stat. Ann. tit. 24, § 1931 (a) to determine if police officers qualify as appointed officers.”
Gadue v. Vill. of Essex Junction, 336 A.2d 182 (Vt. 1975). “§ 1121 empowers municipalities to adopt personnel regulations, this authority is conveyed through the permissive “may” and should not be read as necessarily restricting a village’s dismissal power to local rules which it may or may not adopt.”
Swanson v. Woodstock (Vt. Super. Ct. 2025). · cites it 7× “The village trustees specifically declined, however, to analyze whether the demotion met the “for cause” standard established in 24 V.S.A. §§ 1931–1934. The village trustees reasoned that a finding of “cause” was needed only for terminations of employment, and not for lesser…”
rivard v. brattleboro (Vt. Super. Ct. 2023). · cites it 2× “2 See 24 V.S.A. § 1931(a) (“The legislative body … of a municipality … may establish a police department and appoint police officers ….”
Adam Hubacz v. The Vill. of Waterbury, Vermont & William Shepeluk (Vt. 2015). · cites it 3× “The court also invited the Village Trustees to reconsider whether recourse for firing a police officer was limited to § 1932 or if it might also be based on 24 V.S.A. § 1931. The court explicitly offered “no opinion with respect to [plaintiff’s] legal entitlement to back pay,…”
Show all 17 citing cases →
— Vt. Stat. Ann. tit. 24, § 1931(a) — 11 cases
Nelson v. Town of St. Johnsbury, LaMotte, Oddy, Ruggles, Rust, Timson & Town of St. Johnsbury, 2015 VT 5 (Vt. 2015). “3d 1246 (recognizing that 24 V.S.A. § 1931(a), which states that officers “shall hold office during good behavior, unless sooner removed for cause,” authorizes town to remove police chief only for cause).”
Adam Hubacz v. The Vill. of Waterbury, 187 A.3d 367 (Vt. 2018). “The superior court certified the following question to this Court: Is a State's Attorney's unilateral decision to refuse to prosecute any cases investigated by a particular municipal police officer, alone, a sufficient basis for termination of the officer pursuant to 24 V.S.A. §…”
Turnley v. Town of Vernon, 2013 VT 42 (Vt. 2013). “” 24 V.S.A. § 1931(a). The appointing authority may schedule a hearing to consider charges “[w]henever it appears to the appointing authority .”
Burwell v. Peyton, 131 F. Supp. 3d 268 (D. Vt. 2015). “]” 24 V.S.A. § 1931(a), (b). The state statutes governing municipal police officers and police chiefs thus impose only duties “owed to the community as a whole.”
Hee v. Everlof, 812 F. Supp. 1350 (D. Vt. 1993). “§ 901 (1975) (An action against an appointed municipal officer must be brought against the municipality); 24 V.S.A. § 1931(a) (1975) (police officers are appointed municipal officers).”
— Vt. Stat. Ann. tit. 24, § 1931(b) — 2 cases
White River Amusement Pub. v. Town of Hartford, Vt., 412 F. Supp. 2d 416 (D. Vt. 2005). “§§ 1235-38 (town manager); 24 V.S.A. § 1931(b) (municipal police chief).”
Turnley v. Town of Vernon, 2012 VT 69 (Vt. 2012).
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