Vt. Stat. Ann. » Title 33 Chapter 49
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 33, § 4915 (2026)

✓ current as of May 2026
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Subchapter 002 : REPORTING ABUSE OF CHILDREN

(Cite as: 33 V.S.A. § 4915)
Notes of Decisions
Cited in 27 cases (7 in the last 5 years), 1991–2025 · leading case: Tina Stocker v. State of Vermont, 2021 VT 71 (Vt. 2021).
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Tina Stocker v. State of Vermont, 2021 VT 71 (Vt. 2021). · cites it 8× “Plaintiffs’ only viable legal theory, the court concluded, was that DCF owed plaintiffs a duty to “receive, record, and evaluate reports of abuse under 33 V.S.A. § 4915.” Specifically, it found that the only actionable duty of care was that upon receipt of a report of abuse or…”
Earle v. State, 2006 VT 92 (Vt. 2006). · cites it 10× “There may be circumstances under which the agency responds to a claim of abuse, but its response fails to comply with the mandatory duties established by 33 V.S.A. § 4915, including the duty to promptly investigate claims of abuse, 33 V.”
Sabia v. Neville, 687 A.2d 469 (Vt. 1996). · cites it 4× “Defendants suggest another method of upholding the trial court by arguing that the duties imposed by 33 V.S.A. § 4915 are those of the Commissioner of SRS and not others who work for the Commissioner.”
LaShay v. Dep't of Soc. & Rehab. Servs., 625 A.2d 224 (Vt. 1993). · cites it 2× “There, however, the defendant had complied with 33 V.S.A. § 4915 by conducting an investigation immediately after receiving the report, and the investigation was in conformance with statutory guidelines and the SRS Policy Manual.”
Kaho'ohanohano ex rel. Morales-Kaho'ohanohano v. Dep't of Human Servs., 178 P.3d 538 (Haw. 2008). “As previously mentioned, the Sabia court concluded that the SRS has a duty to protect the plaintiffs from further abuse, explaining that Vermont’s statutory law provides that (1) SRS “shall cause an investigation to commence within seventy-two hours after receipt of a report” of…”
F.E.F. v. Cameron, 594 A.2d 897 (Vt. 1991). · cites it 2× “See 33 V.S.A. § 4915. The applicability of subdivision (c) thus turns on the applicability of the reporting prong.”
Willis S. Sheldon, Individually & as Adm'r of the Est. of Dezirae Sheldon v. Nicholas Ruggiero, 202 A.3d 241 (Vt. 2018). “See 33 V.S.A. § 4915(a) (mandating DCF assessment and investigation "[u]pon receipt of a report of abuse or neglect"); id.”
Chase v. Bowen, 2008 VT 12 (Vt. 2008). “3 We assume that DCF investigated the matter pursuant to its charter to respond to reports of child abuse, see 33 V.S.A. § 4915, but such a response is not necessarily relevant to the family court’s assessment of parental rights and responsibilities.”
Sabia v. State, 669 A.2d 1187 (Vt. 1995). “Regarding the first factor, statutory law provides that (1) SRS “shall cause an investigation to commence within seventy-two hours after receipt of a report” of child abuse, 33 V.S.A. § 4915(a) (emphasis added); (2) the investigation “shall include” a visit to the child’s home…”
Lashay v. Dept. of Soc. & Rehab. Serv., 625 A.2d 224 (Vt. 1993). · cites it 2× “There, however, the defendant had complied with 33 V.S.A. § 4915 by conducting an investigation immediately after receiving the report, and the investigation was in conformance with statutory guidelines and the SRS Policy Manual.”
In re R.H., 2010 VT 95 (Vt. 2010). “§ 4916(a)(1) (requiring that DCF commissioner maintain child protection registry “which shall con *26 tain a record of all investigations that have resulted in a substantiated report on or after January 1, 1992”).”
In Re Appeal of S.C.-M., 2025 VT 48 (Vt. 2025). · cites it 2× “” 33 V.S.A. § 4915(a)-(b), (d). The statute provides, however, that DCF “may conduct an investigation of any report.”
Show all 27 citing cases →
— Vt. Stat. Ann. tit. 33, § 4915(a) — 11 cases
Tina Stocker v. State of Vermont, 2021 VT 71 (Vt. 2021). “Plaintiffs’ only viable legal theory, the court concluded, was that DCF owed plaintiffs a duty to “receive, record, and evaluate reports of abuse under 33 V.S.A. § 4915.” Specifically, it found that the only actionable duty of care was that upon receipt of a report of abuse or…”
Earle v. State, 2006 VT 92 (Vt. 2006). “There may be circumstances under which the agency responds to a claim of abuse, but its response fails to comply with the mandatory duties established by 33 V.S.A. § 4915, including the duty to promptly investigate claims of abuse, 33 V.”
Kaho'ohanohano ex rel. Morales-Kaho'ohanohano v. Dep't of Human Servs., 178 P.3d 538 (Haw. 2008). “As previously mentioned, the Sabia court concluded that the SRS has a duty to protect the plaintiffs from further abuse, explaining that Vermont’s statutory law provides that (1) SRS “shall cause an investigation to commence within seventy-two hours after receipt of a report” of…”
Willis S. Sheldon, Individually & as Adm'r of the Est. of Dezirae Sheldon v. Nicholas Ruggiero, 202 A.3d 241 (Vt. 2018). “See 33 V.S.A. § 4915(a) (mandating DCF assessment and investigation "[u]pon receipt of a report of abuse or neglect"); id.”
Sabia v. State, 669 A.2d 1187 (Vt. 1995). “Regarding the first factor, statutory law provides that (1) SRS “shall cause an investigation to commence within seventy-two hours after receipt of a report” of child abuse, 33 V.S.A. § 4915(a) (emphasis added); (2) the investigation “shall include” a visit to the child’s home…”
— Vt. Stat. Ann. tit. 33, § 4915(b) — 3 cases
Sabia v. Neville, 687 A.2d 469 (Vt. 1996). “Defendants suggest another method of upholding the trial court by arguing that the duties imposed by 33 V.S.A. § 4915 are those of the Commissioner of SRS and not others who work for the Commissioner.”
Wilkinson ex rel. Wilkinson v. Russell, 973 F. Supp. 437 (D. Vt. 1997).
Wilkinson by & Through Wilkinson v. Russell, 973 F. Supp. 437 (D. Vt. 1997).
— Vt. Stat. Ann. tit. 33, § 4915(b)(2) — 2 cases
Wilkinson ex rel. Wilkinson v. Russell, 973 F. Supp. 437 (D. Vt. 1997).
Wilkinson by & Through Wilkinson v. Russell, 973 F. Supp. 437 (D. Vt. 1997).
— Vt. Stat. Ann. tit. 33, § 4915(c) — 4 cases
Earle v. State, 2006 VT 92 (Vt. 2006). “There may be circumstances under which the agency responds to a claim of abuse, but its response fails to comply with the mandatory duties established by 33 V.S.A. § 4915, including the duty to promptly investigate claims of abuse, 33 V.”
F.E.F. v. Cameron, 594 A.2d 897 (Vt. 1991). “See 33 V.S.A. § 4915. The applicability of subdivision (c) thus turns on the applicability of the reporting prong.”
In re M.M., Juv., 2024 VT 28 (Vt. 2024).
In Re Fef, 594 A.2d 897 (Vt. 1991).
— Vt. Stat. Ann. tit. 33, § 4915(d) — 2 cases
Tina Stocker v. State of Vermont, 2021 VT 71 (Vt. 2021). “Plaintiffs’ only viable legal theory, the court concluded, was that DCF owed plaintiffs a duty to “receive, record, and evaluate reports of abuse under 33 V.S.A. § 4915.” Specifically, it found that the only actionable duty of care was that upon receipt of a report of abuse or…”
In Re Appeal of S.C.-M., 2025 VT 48 (Vt. 2025). “” 33 V.S.A. § 4915(a)-(b), (d). The statute provides, however, that DCF “may conduct an investigation of any report.”
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