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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Andrus v. Dunbar, 178 Vt. 554 (2005)

Citation
Andrus v. Dunbar, 178 Vt. 554 (2005)
Parent Document
Andrus v. Dunbar, 178 Vt. 554 (2005)
Jurisdiction
Vermont (state)
Effective Date
2005-04-13

Full Text

881 chars
¶ 12. We conclude that the landlord’s second notice voided the May 1 notice, and therefore do not reach tenant’s other alleged deficiencies in the May 1 notice. In the past, this Court has decided that a landlord waives his right to forfeiture as a matter of law if he receives rent accruing after the forfeiture. Mayo v. Claflin, 93 Vt. 76, 80, 106 A. 653, 655 (1919); Maidstone v. Stevens, 7 Vt. 487, 491 (1835). We explained in Mayo that when a landlord accepts rent this conduct “unequivocally recognize[s] the tenancy as existing” on the last date of the payment period. 93 Vt. at 81, 106 A. at 655. Thus, the landlord waived the notice to quit and the right to termination. Id.; see also Rosenberg v. Taft, 94 Vt. 458, 465, 111 A. 583, 586 (1920) (holding that acceptance of rent waived “right of re-entry for prior breaches of covenant”). The rationale of Mayo applies here.