Vt. Stat. Ann. » Title 27 Chapter 5
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 27, § 604 (2026)

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Subchapter 007 : MARKETABLE RECORD TITLE

(Cite as: 27 V.S.A. § 604)
Notes of Decisions
Cited in 5 cases, 1983–2020 · leading case: Holly Bartlett v. John Roberts & LaLauni Rawls, 2020 VT 24, 231 A.3d 171.
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Holly Bartlett v. John Roberts & LaLauni Rawls, 2020 VT 24, 231 A.3d 171. “” 27 V.S.A. § 604(a)(6). This provision applies to any easement that is clearly observable by physical evidence of its use, whether it is a power line, a septic pipe, or something else.”
Traders, Inc. v. Bartholomew, 459 A.2d 974 (Vt. 1983). “27 V.S.A. § 604(a) (6). 1969, No. 235 (Adj.”
Matthew Gray & Erik Gray v. Martha Treder, John Muscarelle, Robert Muscarelle, Joseph Muscarelle, III, Anne Herrera, Edward F. Godfrey, Judith C. Godfrey, 2018 VT 137, 204 A.3d 1117. · cites it 2× “" 27 V.S.A. § 604(a)(6), (7). By contrast, plaintiffs' construction of the statute would except from extinguishment easements arising in the distant past by operation of law, in some cases based on factors such as topography that may not be reflected in the land records.”
Gray v. Treder, No. 88 (Vt. Super. Ct. May 14, 2015). · cites it 3× “For the foregoing reasons, the Marketable Record Title Act has no effect on the Grays’ easement by necessity. 1The Grays also argue that the exception to the Act for an easement “the existence of which is clearly observable by physical evidences of its use” also applies.”
Nummelin v. Huneck, No. 38 (Vt. Super. Ct. Nov. 29, 2004). “10 27 V.S.A. §604 (a)(7). A right of way of necessity qualifies as an exception because it is created by implication from the deed that created the landlocked parcel.”
Vt. Stat. Ann. tit. 27, § 604(a): 1 case
Traders, Inc. v. Bartholomew, 459 A.2d 974 (Vt. 1983). “27 V.S.A. § 604(a) (6). 1969, No. 235 (Adj.”
Vt. Stat. Ann. tit. 27, § 604(a)(6): 3 cases
Holly Bartlett v. John Roberts & LaLauni Rawls, 2020 VT 24, 231 A.3d 171. “” 27 V.S.A. § 604(a)(6). This provision applies to any easement that is clearly observable by physical evidence of its use, whether it is a power line, a septic pipe, or something else.”
Matthew Gray & Erik Gray v. Martha Treder, John Muscarelle, Robert Muscarelle, Joseph Muscarelle, III, Anne Herrera, Edward F. Godfrey, Judith C. Godfrey, 2018 VT 137, 204 A.3d 1117. “" 27 V.S.A. § 604(a)(6), (7). By contrast, plaintiffs' construction of the statute would except from extinguishment easements arising in the distant past by operation of law, in some cases based on factors such as topography that may not be reflected in the land records.”
Gray v. Treder, No. 88 (Vt. Super. Ct. May 14, 2015). “For the foregoing reasons, the Marketable Record Title Act has no effect on the Grays’ easement by necessity. 1The Grays also argue that the exception to the Act for an easement “the existence of which is clearly observable by physical evidences of its use” also applies.”
Vt. Stat. Ann. tit. 27, § 604(a)(7): 2 cases
Matthew Gray & Erik Gray v. Martha Treder, John Muscarelle, Robert Muscarelle, Joseph Muscarelle, III, Anne Herrera, Edward F. Godfrey, Judith C. Godfrey, 2018 VT 137, 204 A.3d 1117. “" 27 V.S.A. § 604(a)(6), (7). By contrast, plaintiffs' construction of the statute would except from extinguishment easements arising in the distant past by operation of law, in some cases based on factors such as topography that may not be reflected in the land records.”
Gray v. Treder, No. 88 (Vt. Super. Ct. May 14, 2015). “For the foregoing reasons, the Marketable Record Title Act has no effect on the Grays’ easement by necessity. 1The Grays also argue that the exception to the Act for an easement “the existence of which is clearly observable by physical evidences of its use” also applies.”
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