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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 24, § 4454 (2026)

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

(Cite as: 24 V.S.A. § 4454)
Notes of Decisions
Cited in 40 cases (11 in the last 5 years), 2005–2025 · leading case: In re 204 North Avenue NOV (Pierre Gingue, Appellant), 2019 VT 52 (Vt. 2019).
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In re 204 North Avenue NOV (Pierre Gingue, Appellant), 2019 VT 52 (Vt. 2019). · cites it 4× “115 §§ 101, 119(c) (amending and recodifying statute of limitations at 24 V.S.A. § 4454). More specifically, the Legislature explained that it intended to eliminate the “costs and problems arising from” this Court’s decision in Bianchi v.”
In re Appeal of Tekram Partners, 2005 VT 92 (Vt. 2005). · cites it 2× “Tekram Partners complain that the fifteen-year limitations period under 24 V.S.A. § 4454 (formerly §4496 1 ) precludes the City’s enforce *629 ment of this violation because the dumpster has been in the same location since 1975.”
op21-131.pdf, 2022 VT 37 (Vt. 2022). · cites it 3× “It also held that a 2014 interior reconfiguration by owners did not change the property’s use, and the zoning statute of limitations, 24 V.S.A. § 4454(a), barred the City’s enforcement action in any case.”
In re 15-17 Weston Street NOV (Keith S. Aaron, Weston Street Trust, Appellant), 2021 VT 85 (Vt. 2021). · cites it 4× “We conclude that the City is not precluded from enforcing the zoning violation on account of 24 V.S.A. § 4454 because a valid municipal ordinance establishes that if an unlawful use is discontinued for more than sixty days, resumption of the unlawful use 1 Keith Aaron is the…”
In re Purvis Nonconforming Use (Luke Purvis, Appellant), 2019 VT 60 (Vt. 2019). “Purvis appealed to the Development Review Board, arguing that the expansion of the parking area was an unenforceable permit violation under 24 V.S.A. § 4454, as the expansion first occurred over fifteen years ago.”
In Re Hale Mountain Fish & Game Club, Inc., 2014 VT 54 (Vt. 2014). “After denying neighbors’ motion for summary judgment in a March 2008 decision, the Environmental Division issued a supplemental interim decision in November 2008 denying the parties’ cross-motions for summary judgment on the ultimate question of whether Hale Mountain had…”
15-17 Weston Street NOV - Decision on Motion (Vt. Super. Ct. 2021). · cites it 16× “2 is ultra vires and its role in the Vermont Supreme Court’s interpretation of 24 V.S.A. § 4454. As a final point, we examine whether the Trust’s rental of Unit # 1 was previously litigated.”
Benoit Conversion Application - Decision on Motion (Vt. Super. Ct. 2021). · cites it 10× “(stating that the Environmental Court did not err in declining to address 24 V.S.A. § 4454). Approximately eleven years later, the Supreme Court revisited this Court’s application of 24 V.”
204 North Avenue NOV - Decision on Motion (Vt. Super. Ct. 2018). · cites it 8× “Gingue’s Statement of Questions asks whether “[t]he enforcement action is barred by the Statute of Limitations, 24 V.S.A. § 4454(a).”1 Mr. Gingue and the City ask the Court to answer the Question in the affirmative and negative, respectively.”
Beauregard NOV (Vt. Super. Ct. 2016). · cites it 7× “their permit application, and because the Town approved that proposal, the Town may not now challenge the location of the garage; (2) removal of the box trailer was not a permit condition; and (3) both the trailer and the Quonset hut have been in place for more than fifteen…”
Purvis Nonconforming Use (Vt. Super. Ct. 2016). · cites it 7× “Appellant argues that his parking is protected by 24 V.S.A. § 4454, which establishes a fifteen-year statute of limitations upon the enforcement of zoning violations, and also that his parking is a nonconforming use.”
Bundy Staniford Road - Decision on Motion (Vt. Super. Ct. 2021). · cites it 7× “-9- withdrawing the protections provided, including the limitations barring enforcement contained in 24 V.S.A. § 4454, against long-standing zoning violations that are discontinued for more than 60 days.”
Show all 40 citing cases →
— Vt. Stat. Ann. tit. 24, § 4454(a) — 36 cases
In re 204 North Avenue NOV (Pierre Gingue, Appellant), 2019 VT 52 (Vt. 2019). “115 §§ 101, 119(c) (amending and recodifying statute of limitations at 24 V.S.A. § 4454). More specifically, the Legislature explained that it intended to eliminate the “costs and problems arising from” this Court’s decision in Bianchi v.”
op21-131.pdf, 2022 VT 37 (Vt. 2022). “It also held that a 2014 interior reconfiguration by owners did not change the property’s use, and the zoning statute of limitations, 24 V.S.A. § 4454(a), barred the City’s enforcement action in any case.”
In re 15-17 Weston Street NOV (Keith S. Aaron, Weston Street Trust, Appellant), 2021 VT 85 (Vt. 2021). “We conclude that the City is not precluded from enforcing the zoning violation on account of 24 V.S.A. § 4454 because a valid municipal ordinance establishes that if an unlawful use is discontinued for more than sixty days, resumption of the unlawful use 1 Keith Aaron is the…”
In Re Hale Mountain Fish & Game Club, Inc., 2014 VT 54 (Vt. 2014). “After denying neighbors’ motion for summary judgment in a March 2008 decision, the Environmental Division issued a supplemental interim decision in November 2008 denying the parties’ cross-motions for summary judgment on the ultimate question of whether Hale Mountain had…”
15-17 Weston Street NOV - Decision on Motion (Vt. Super. Ct. 2021). “2 is ultra vires and its role in the Vermont Supreme Court’s interpretation of 24 V.S.A. § 4454. As a final point, we examine whether the Trust’s rental of Unit # 1 was previously litigated.”
— Vt. Stat. Ann. tit. 24, § 4454(c) — 1 case
Hale Mountain Fish & Game Club (Vt. Super. Ct. 2008).
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