Nor does it overcome the common law rule outlined above that Limoge’s mailing
constituted acceptance of Campbell’s offer to extend his tenancy through August 31, 2025.
Because Limoge mailed that letter by certified and first-class mail to Campbell’s Apartment
address – accepting by the same method (mail) sent to the same address from which Campbell
sent his offer – the court rules that her June 25, 2025 letter constituted acceptance of Campbell’s
offer to extend his Apartment tenancy through August 31, 2025. Vermont law deems Limoge’s
June 25, 2025 letter received by Campbell on June 28, 2025. See 9 V.S.A. §4451 (containing
definition of “actual notice”). Limoge’s June 25, 2025 letter lawfully served as a no-cause
termination notice effective as of August 31, 2025 because it provided more than 60 days’ notice
where Campbell had lived at the Apartment for under two years. See 9 V.S.A. §4467(c)(1)(A).
As a result, Limoge properly applied Campbell’s security deposit to his unpaid July 2025 rent. 2
Order