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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

215 summer street v thibodeau, No. 23-cv-5356 (Vt. Super. Ct. 2026)

Citation
215 summer street v thibodeau, No. 23-cv-5356 (Vt. Super. Ct. 2026)
Parent Document
215 summer street v thibodeau, No. 23-cv-5356 (Vt. Super. Ct. 2026)
Jurisdiction
Vermont (state)
Effective Date
2026-01-07

Full Text

1,065 chars
[t]he trial court … properly ruled that the claims based on the termination notices
of January 3 and January 17 had not properly accrued, as the lawsuit was filed
prior to the stated termination dates. The statute provides that “[i]f the tenant
remains in possession after termination of the rental agreement … the landlord
may bring an action for possession.” 9 V.S.A. § 4468 [emphasis deleted]. The
lawsuit filed on January 11 was therefore premature as to those notices with later
termination dates. See Avdich v. Kleinert, 69 Ill.2d 1, 12 Ill.Dec. 700, 370 N.E.2d
504, 508 (Ill. 1977) (plaintiff landlord was not entitled to possession until after
expiration of stated termination date and therefore could not maintain action to
recover possession prior to that time); Hous. Auth. of the City of Newark v.
Caldwell, 247 N.J.Super. 595, 589 A.2d 1088, 1089 (N.J. Super Ct. Law Div.
1991) (filing complaint for possession prior to expiration of required termination
period means cause of action has not accrued, and court lacks jurisdiction to
dispossess tenant).