Vermont Statutes Annotated
Vt. Stat. Ann. tit. 24, § 4447 (2026)
Clerk’s certificate
✓ current as of May 2026
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Subchapter 009 : ADOPTION, ADMINISTRATION, AND ENFORCEMENT
(Cite as: 24 V.S.A. § 4447)-
§ 4447. Clerk’s certificate
A certificate of the clerk of a municipality showing the publication, posting, consideration, and adoption or amendment of a plan, bylaw, or capital budget or program shall be presumptive evidence of the facts as they relate to the lawful adoption or amendment of that plan, bylaw, or capital budget or program, so stated in any action or proceeding in court or before any board, commission, or other tribunal. (Added 2003, No. 115 (Adj. Sess.), § 100.)
Notes of Decisions
Cited in 7
cases, 1971–2013 · leading case: In Re Appeal of Fish, 554 A.2d 256 (Vt. 1988).
In Re Appeal of Fish, 554 A.2d 256 (Vt. 1988). “On August 21, appellants’ attorney hand-delivered a letter to the Board objecting to the scheduling of the August 21 session without the notice specified in 24 V.S.A. § 4447, and requested that the meeting be adjourned with proper notice of a new date.”
Kalakowski v. Town of Clarendon, 431 A.2d 478 (Vt. 1981). “§ 4404(a); that there be adequate public notice of a final hearing, 24 V.S.A. § 4447; and that there be proper warnings of upcoming votes, as demanded in 24 V.”
Town of Mendon v. Ezzo, 278 A.2d 726 (Vt. 1971). “He contends that the validity of emergency zoning demands compliance with all of the provisions of 24 V.S.A. § 4447 of the Planning and Development Act.”
S. Vermont Beagle Club (Vt. Super. Ct. 2013). “§ 4464(a), formerly codified as 24 V.S.A. § 4447). At their core, notice requirements protect due process and fundamental administrative fairness in municipal adjudicative proceedings.”
Nye Conditional Use Permit (Vt. Super. Ct. 2012). “§ 4464(a), formerly codified as 24 V.S.A. § 4447). Despite Neighbor’s argument that the notice for the meeting on April 1, 2009 Was inadequate, he was informed about Applicant’s proposal and he took advantage of the opportunity to provide comments on that proposal during the…”
Norris Subdivision Application (Vt. Super. Ct. 2006). “]” 24 V.S.A. § 4447(a)(1–2) (2003). The Zoning Administrator complied with the applicable notice requirements, and indeed went beyond the applicable notice requirements by providing notice as to the time of the hearing, and by posting the information in three public places.”
Appeal of Walters (Vt. Super. Ct. 2005). “The plain meaning of that unambiguous section of the Municipal Administrative Procedures Act is that the notice of a hearing only requires notice of an opportunity for all interested persons to be heard, and compliance with 24 V.S.A. § 4447, which requires that notice ―be given…”
— Vt. Stat. Ann. tit. 24, § 4447(a) — 2 cases
In Re Appeal of Fish, 554 A.2d 256 (Vt. 1988). “On August 21, appellants’ attorney hand-delivered a letter to the Board objecting to the scheduling of the August 21 session without the notice specified in 24 V.S.A. § 4447, and requested that the meeting be adjourned with proper notice of a new date.”
Norris Subdivision Application (Vt. Super. Ct. 2006). “]” 24 V.S.A. § 4447(a)(1–2) (2003). The Zoning Administrator complied with the applicable notice requirements, and indeed went beyond the applicable notice requirements by providing notice as to the time of the hearing, and by posting the information in three public places.”
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