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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 24, § 4451 (2026)

✓ current as of May 2026
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Subchapter 009 : ADOPTION, ADMINISTRATION, AND ENFORCEMENT

(Cite as: 24 V.S.A. § 4451)
Notes of Decisions
Cited in 100 cases (32 in the last 5 years), 2006–2026 · leading case: In re Beliveau NOV, Town of Fairfax v. Beliveau, 2013 VT 41 (Vt. 2013).
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In re Beliveau NOV, Town of Fairfax v. Beliveau, 2013 VT 41 (Vt. 2013). · cites it 3× “Homeowner believed the fine, if any, to be the cost of the zoning permit application. Pursuant to 24 V.S.A. § 4451(a), the court imposed a penalty of $63,142, or $56.”
In Re Appeal of Trahan Nov, 2008 VT 90 (Vt. 2008). “See 24 V.S.A. § 4451(a) (stating that the fines required under the section reflect the number of days that a violation is ongoing).”
City of St. Albans v. Hayford, 2008 VT 36 (Vt. 2008). “24 V.S.A. § 4451(a). The court has the discretion to determine the amount of a fine, and, in doing so, to balance any continuing violation against the cost of compliance and to consider other relevant factors, including those specified in the Uniform Environmental Enforcement…”
Fly Fish Vermont, Inc. v. Chapin Hill Estates, Inc., 2010 VT 33 (Vt. 2010). “See, e.g., 10 V.S.A. §§ 1274 & 1275 (authorizing enforcement for violations of discharge permits and setting penalties for permit violations, including imprisonment of up to six months per violation); 24 V.”
Town of Pawlet v. Daniel Banyai, 2022 VT 4 (Vt. 2022). “24 V.S.A. § 4451(a), (a)(3). When determining a fine, the Environmental Division must “balance any continuing violation against the cost of compliance and .”
Town of Plainfield v. Lynch, Lynch & Parry - Decision on the Merits (Vt. Super. Ct. 2025). · cites it 8× “§ 1974a or (2) an enforcement action pursuant to 24 V.S.A. §§ 4451, 4452. Section 2.5 provides that: In accordance with 24 V.”
Town of South Hero v. Zlotoff Found., Inc Air Dev. Inc., - Decision on Motion (Vt. Super. Ct. 2020). · cites it 7× “Defendants argue that the Museum NOV is void because it is deficient under 24 V.S.A. § 4451; it is fundamentally misleading; and it provides insufficient notice under principles of due process.”
110 Riverside Avenue NOV Appeal & City of Burlington v. Sisters & Bros. - Decision on Motions (Vt. Super. Ct. 2025). · cites it 7× “§ 4452 (setting forth the remedies available to a municipality if a zoning violation occurs); 24 V.S.A. § 4451 (setting forth the process by which a municipality may enforce its zoning regulations against a violator and recover fines); V.”
Town of Richmond v. Cowan (Vt. Super. Ct. 2008). · cites it 8× “The Environmental Court has jurisdiction of only three types of enforcement actions that can result in fines or monetary penalties: under the statute governing state environmental enforcement orders2; under the statute governing municipal solid waste orders3; and under 24 V.S.A.…”
Town of Newbury v. Celeste (Vt. Super. Ct. 2010). · cites it 7× “} Decision and Order on Defendant’s Motion for Summary Judgment This case is an enforcement proceeding brought by the Town of Newbury against Defendant Joseph Celeste, under the authority of 24 V.S.A. § 4451 and § 4452, for violations of the Town of Newbury Zoning Regulations as…”
Town of Marshfield v. Harris - Decision on Merits (Vt. Super. Ct. 2024). · cites it 4× “These decisions established that Respondent was required to obtain a conditional use permit, which he failed to do before operating the Camp between July 25, 2021 and August 1, 2021. Accordingly, having established that a violation occurred for these eight days, the only issue…”
Town of Colchester v. Andres (Vt. Super. Ct. 2014). · cites it 6× “(citing 24 V.S.A. § 4451(a)). Our decision here is based upon the limited remand directive from the Supreme Court “to reconsider the fine to be imposed within th[e] timeframe” of Defendant’s zoning violation.”
Show all 100 citing cases →
— Vt. Stat. Ann. tit. 24, § 4451(A)(1) — 1 case
Town of Rockingham v. Van Schoick - Decision on Motions (Vt. Super. Ct. 2024).
— Vt. Stat. Ann. tit. 24, § 4451(a) — 50 cases
In re Beliveau NOV, Town of Fairfax v. Beliveau, 2013 VT 41 (Vt. 2013). “Homeowner believed the fine, if any, to be the cost of the zoning permit application. Pursuant to 24 V.S.A. § 4451(a), the court imposed a penalty of $63,142, or $56.”
In Re Appeal of Trahan Nov, 2008 VT 90 (Vt. 2008). “See 24 V.S.A. § 4451(a) (stating that the fines required under the section reflect the number of days that a violation is ongoing).”
City of St. Albans v. Hayford, 2008 VT 36 (Vt. 2008). “24 V.S.A. § 4451(a). The court has the discretion to determine the amount of a fine, and, in doing so, to balance any continuing violation against the cost of compliance and to consider other relevant factors, including those specified in the Uniform Environmental Enforcement…”
Town of Pawlet v. Daniel Banyai, 2022 VT 4 (Vt. 2022). “24 V.S.A. § 4451(a), (a)(3). When determining a fine, the Environmental Division must “balance any continuing violation against the cost of compliance and .”
Town of South Hero v. Zlotoff Found., Inc Air Dev. Inc., - Decision on Motion (Vt. Super. Ct. 2020). “Defendants argue that the Museum NOV is void because it is deficient under 24 V.S.A. § 4451; it is fundamentally misleading; and it provides insufficient notice under principles of due process.”
— Vt. Stat. Ann. tit. 24, § 4451(a)(1) — 1 case
Town of Pawlet v. Banyai - Decision on Motion (Vt. Super. Ct. 2020).
— Vt. Stat. Ann. tit. 24, § 4451(a)(2)(A) — 3 cases
Town of Duxbury v. Kessler - Decision on Motion (Vt. Super. Ct. 2024).
Lonie Parker DBA Porky's Bkyd BBQ SP & NOV - Decision on Motion (Vt. Super. Ct. 2020).
City of St. Albans v. Hayford - Decision on Motion (Vt. Super. Ct. 2021).
— Vt. Stat. Ann. tit. 24, § 4451(a)(3) — 5 cases
15-17 Weston Street NOV - Decision on Motion (Vt. Super. Ct. 2021).
Burns 12 Weston Street NOV - Decision on Motion (Vt. Super. Ct. 2021).
Town of Rockingham v. Van Schoick - Decision on the Merits (Vt. Super. Ct. 2025).
Town of Duxbury v. Kessler - Decision on Merits (Vt. Super. Ct. 2025).
Town of Whitingham v. Two Lakes, LLC - Merits Decision (Vt. Super. Ct. 2026).
— Vt. Stat. Ann. tit. 24, § 4451(b) — 1 case
Town of Westford v. Mathieu Props., LLC (Vt. Super. Ct. 2013).
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