Paige V State
VERMONT SUPERIOR COURT CIVIL DIVISION
Washington Unit Case No. 24-CV-04712
65 State Street
Montpelier VT 05602
802-828-2091
www.vermontjudiciary.org
H. Paige v. State of Vermont et al
Opinion and Order on Mr. Paige’s Motion for Reconsideration
Plaintiff Mr. H. Brooke Paige brought this case challenging several features of
Vermont election law included in legislation from 2021 (Act 60) (“An act relating to
mailing out ballots, correcting defective ballots, and miscellaneous changes to State
election laws.”). On April 3, 2025, the Court granted the State’s motion to dismiss,
pursuant to both Vt. R. Civ. P. 12(b)(1) and (6), concluding that he had failed to
adequately plead any claim under 17 V.S.A. § 2603 and that the allegations of the
complaint were conclusory and insufficient to demonstrate standing to pursue his other
potential claims.
Mr. Paige has filed a motion to reconsider. He takes umbrage that the Court
described certain of the allegations of the complaint as allegations when such assertions
could have been easily verified, presumably if the Court had undertaken its own ex parte
investigation into the facts. He says that the Court’s word-choice “lessens the Plaintiff’s
assumption of the Court’s impartial consideration of the facts.” Additionally, he argues
that the Court improperly interpreted 17 V.S.A. § 2603 narrowly when it should have
interpreted it broadly, and he provides further argument as to why he thinks he has
standing in this case.
Order Page 1 of 4
24-CV-04712 H. Paige v. State of Vermont et al
I. Procedural Standard
Mr. Paige’s motion to reconsider sounds in the Court’s power to alter or amend its
prior judgment under Vt. R. Civ. P. 59(e). “Rule 59(e) motions to alter or amend
judgment allow ‘the trial court to revise its initial judgment if necessary to relieve a
party against the unjust operation of a record resulting from the mistake or inadvertence
of the court and not the fault or neglect of a party.’ A Rule 59(e) motion ‘must clearly
establish either a manifest error of law or fact or must present newly discovered
evidence.’” Sutton v. Purzycki, 2022 VT 56, ¶ 67 (citations omitted). The Rule has a
“narrow aim,” N. Sec. Ins. Co. v. Mitec Elecs., Ltd., 2008 VT 96, ¶ 41, 184 Vt. 303, 319
(internal quotation omitted); and constitutes “an extraordinary remedy that should be
used sparingly,” 11 C. Wright, et al., Fed. Prac. & Proc. Civ. § 2810.1 (3d ed.)
II. Analysis
A. Bias and the words Alleges/Allegations
The Court’s use of the words alleges and allegations in its ruling reflects no bias
against Mr. Paige. The Court referred to the allegations of the complaint, facts that Mr.
Paige alleged, because that is what facts asserted in a complaint are. Rule 8(e)(1)
provides that the averments “of a pleading shall be simple, concise, and direct.” See also
Vt. R. Civ. P. 10(b) (“All averments of claim or defense shall be made in numbered
paragraphs, the contents of each of which shall be limited as far as practicable to a
statement of a single set of circumstances; and a paragraph may be referred to by
number in all succeeding pleadings.”). An averment is an allegation of fact. Black’s Law
Dictionary 131–32 (7th ed. 1999).
Order Page 2 of 4
24-CV-04712 H. Paige v. State of Vermont et al
The procedural standards, explicitly described in the dismissal decision, required
the Court to accept as true all nonconclusory allegations of fact in the complaint. See,
e.g., Town of Bridgewater v. Dep't of Taxes, 173 Vt. 509, 510, 787 A.2d 1234, 1236 (2001)
(mem.) (In examining a motion to dismiss, “all uncontroverted factual allegations of the
complaint accepted as true and construed in the light most favorable to the nonmoving
party.”). The Court did so.
Further, Courts have limitations on their ability to conduct independent
investigations into the facts. Rule 2.9(c), Vt. Code. Jud. Cond. 2019 (“A judge shall not
investigate facts in a matter independently and shall consider only the evidence
presented and any facts that may properly be judicially noticed.”); see also id. cmt. [6]
(“The prohibition against a judge investigating the facts in a matter extends to
information available in all mediums, including electronic.”). It had no duty to verify Mr.
Paige’s allegations, and any attempt at doing may have been beyond its proper duties.
More importantly, as noted, in making its ruling, it accepted the veracity of all
nonconclusory allegations of the complaint.
B. Interpretation of 17 V.S.A. § 2603
Mr. Paige’s argument as to the proper interpretation of § 2603 is not persuasive.
Applicable precedents are clear and were referenced in the dismissal decision.
Mr. Paige’s principal arguments are that something about the legislative history of
§ 2603 suggests that the Court got it wrong, and that he consulted with an ex-legislator
and an ex-governor, and now represents that each has some general view as to the
intended breadth of § 2603. If Mr. Paige sought to rely on such arguments, he should
have raised them in his opposition briefing. It is too late now. A party may not wait for
Order Page 3 of 4
24-CV-04712 H. Paige v. State of Vermont et al
reconsideration to “wheel out all its artillery.” Caisse Nationale de Credit Agricole v. CBI
Industries, Inc., 90 F.3d 1264, 1270 (7th Cir. 1996) (quoting Employers Ins. of Wausau v.
Bodi Wachs Aviation Ins. Agency, 846 F. Supp. 677, 685 (N.D. Ill. 1994)). In any event,
such arguments based on the views and memories individual political actors are not
persuasive. See In re Investigation to Rev. Avoided Costs that Serve as Prices for
Standard-Offer Program in 2020, 2021 VT 59, ¶ 14, 215 Vt. 247, 253 (“In considering
legislative history, however, the comments of individual legislators typically carry little
weight.” (internal quotation omitted)).
C. Standing
Otherwise, Mr. Paige provides additional argumentation as to standing but
nowhere clearly identifies what controlling authority or facts he thinks the Court
overlooked. The appearance is that he is merely, and improperly, seeking to relitigate a
matter that already has been decided. That is insufficient to provide a solid basis for
altering a judgment under Rule 59. “[A] motion to reconsider should not be granted
where the moving party seeks solely to relitigate an issue already decided.” Latouche v.
North Country Union High School Dist., 131 F. Supp. 2d 568, 569 (D. Vt. 2001).
The Court perceives no basis for reconsideration.
Conclusion
For the foregoing reasons, Mr. Paige’s motion to reconsider is denied.
Electronically signed on Monday, July 7, 2025, per V.R.E.F. 9(d).
_______________________
Timothy B. Tomasi
Superior Court Judge
Order Page 4 of 4
24-CV-04712 H. Paige v. State of Vermont et al