The outcome of this case depends on the legal significance of Limoge having accepted
Campbell’s offer to extend his tenancy through August 31, 2025, even though he testified he did
not timely receive it. Vermont’s common and statutory law indicate on these facts that Limoge
validly extended Campbell’s Apartment tenancy through August 31, 2025 by sending her June
25, 2025 acceptance to Campbell at the Apartment address by certified and first-class mail. "An
acceptance sent by mail or otherwise from a distance is not operative when dispatched, unless it
is properly addressed and such other precautions taken as are ordinarily observed to insure safe
transmission of similar messages." Restatement (Second) of Contracts §66 (1981). "The offeree
[Limoge] may fulfill the requirement that an acceptance be properly addressed by using a return
address indicated in the offer, whether in a letterhead or otherwise." Id. Cmt. b. "[I]f a letter
comes into . . . a place which the person has designated as the place for this or similar
communications to be deposited, the communication has reached its destination and is effectual
without regard to whether it is actually read." 2 Williston on Contracts § 6:46 (4th ed. 2025).
These principles align with Vermont’s law governing residential rental agreements. E.g., 9
V.S.A. §4451 (defining “actual notice” as “receipt of written notice hand-delivered or mailed to
the last known address” and providing a “rebuttable presumption that the notice was received
three days after mailing is created if the sending party proves that the notice was sent by first-
class or certified U.S. mail”).