Garcia v. Birch (2024)

Citation: Garcia v. Birch (2024)
Parent Document: Garcia v. Birch (2024)
Jurisdiction: Vermont (state)
Effective Date: 2024-09-23
Original Source: https://www.courtlistener.com/opinion/10124239/garcia-v-birch/ ↗

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This does not mean that landlord has to spell out the nature of each and every violation or
cite the publicly available statutes at length, but it does mean that they must provide some notice to
allow tenant to correct the issue or challenge it if there has been an error. In this respect, the Court
would analogize the need for clarity under Section 4467(b) to the requirements for pleadings that
require only notice of the allegations. See Huntington Ingalls Industries, Inc. v. Ace American Insurance Co.,
2022 VT 45, ¶¶ 40 (complaints need only make a “bare bones statement that merely provides the
defendant with notice of the claims against it”); see also Bock v. Gold, 2008 VT 81, ¶ 4 (mem.)
(holding that notice pleading standards are exceedingly low). A notice of termination under Sections
4467(b)(1) and (2) should not carry a higher standard than what the eventual pleading will require,

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