Daniel Shaffer, in His Capacity as the Administrator of the Estate of Jared T. Shaffer v. Northeast Kingdom Human Services, Inc.

2025 VT 31
CourtSupreme Court of Vermont
DecidedJune 20, 2025
Docket24-AP-174
StatusPublished
Cited by2 cases

This text of 2025 VT 31 (Daniel Shaffer, in His Capacity as the Administrator of the Estate of Jared T. Shaffer v. Northeast Kingdom Human Services, Inc.) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniel Shaffer, in His Capacity as the Administrator of the Estate of Jared T. Shaffer v. Northeast Kingdom Human Services, Inc., 2025 VT 31 (Vt. 2025).

Opinion

NOTICE: This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports. Readers are requested to notify the Reporter of Decisions by email at: Reporter@vtcourts.gov or by mail at: Vermont Supreme Court, 109 State Street, Montpelier, Vermont 05609-0801, of any errors in order that corrections may be made before this opinion goes to press.

2025 VT 31

No. 24-AP-174

Daniel Shaffer, In His Capacity as the Administrator Supreme Court of the Estate of Jared T. Shaffer

On Appeal from v. Superior Court, Caledonia Unit, Civil Division

Northeast Kingdom Human Services, Inc. February Term, 2025

Daniel P. Richardson, J.

David S. Shaffer, Pro Se, Greenwich, Connecticut, Plaintiff-Appellant.

Richard Windish and Elizabeth Willhite of Primmer, Piper, Eggleston & Cramer, Woodstock, for Defendant-Appellee.

PRESENT: Reiber, C.J., Eaton, Carroll, Cohen and Waples, JJ.

¶ 1. REIBER, C.J. In this wrongful-death action, plaintiff the Estate of Jared

Shaffer, through Daniel Shaffer as administrator, appeals from a jury verdict and judgment in

favor of defendant Northeast Kingdom Human Services, Inc. The estate argues the court erred

by instructing the jury on comparative negligence, by providing jury instructions that it claims

were misleading, and by sustaining defendant’s objections to certain questions the estate

attempted to ask defendant’s corporate representative at trial. The estate further argues the jury

verdict must be reversed because the jury deliberated too quickly and because the evidence

overwhelmingly supported the estate’s claim that defendant acted negligently in performing its duty to oversee and monitor developmental disabilities services and care for decedent. We find

error in the proceedings but no prejudice to the estate and therefore affirm.

I. Factual Background

¶ 2. The record reveals the following facts. The estate’s claims arise out of the death

of decedent Jared Shaffer, a developmentally disabled adult. Decedent passed away on April

18, 2017. He had multiple disabilities, including autism, epilepsy, obsessive-compulsive

disorder, and anxiety. Decedent’s residence at the time of his death was Heartbeet Lifesharing,

a therapeutic community residence in Hardwick, Vermont. Defendant Northeast Kingdom

Human Services, Inc. was the designated agency1 assigned to administer decedent’s Medicaid

waiver funds. His primary care provider was Peter Sher, M.D., an employee of the Hardwick

Area Health Center. Heartbeet was decedent’s residential provider and ensured that he attended

medical appointments. Daniel Shaffer, decedent’s father, was decedent’s court-appointed legal

co-guardian, along with decedent’s mother, Susan Gilberg. On July 11, 2017, father was

appointed the administrator of decedent’s estate.

¶ 3. Days before decedent’s death, he visited his father in Connecticut. He stayed at

father’s home between April 14 and April 17, 2017. During this visit, father observed that

decedent’s affect had changed, he had lost weight, and he was breathing heavily. Father

contacted Heartbeet to request that decedent return to Vermont and see his primary care

provider.

¶ 4. Decedent returned to Vermont on April 17, 2017. That same day, Heartbeet took

him to see Dr. Sher. Dr. Sher did not perform a cancer screening, and did not send decedent to

1 Section 7252 of Title 18 defines “[d]esignated agency” as a “designated community mental health and developmental disability agency.” This entity is tasked with “ensur[ing] that community services to persons with a mental condition or psychiatric disability and persons with a developmental disability throughout the State are provided through designated community mental health agencies.” 18 V.S.A. § 8907(a). 2 the hospital. The next day, on April 18, decedent suffered a sudden and acute pulmonary

embolism and died. The autopsy revealed that decedent had testicular cancer. The cancer had

metastasized to his lungs, liver, and lymph nodes causing the fatal embolism.

II. Procedural History

¶ 5. The estate first sued Heartbeet, Dr. Sher, and defendant in federal court. In April

2021, the federal case was dismissed for lack of subject matter jurisdiction after the estate settled

with Dr. Sher’s medical practice.

¶ 6. The estate, by its administrator Daniel Shaffer, filed this wrongful-death action

in the civil division against defendant and Heartbeet in May 2021. The estate asserted claims

of negligence, negligence per se, and breach of contract against both defendant and Heartbeet.

Before the evidence opened at trial, Heartbeet settled, and the case was tried only against

defendant Northeast Kingdom Human Services, Inc.

¶ 7. Defendant never sought to add father, as a party. But in its answer, defendant

asserted an affirmative defense under 12 V.S.A. § 1036 stating: “Comparative and/or

contributory negligence sufficient to bar plaintiff’s claims for relief.” Defendant sought to

implicate father as responsible for his son’s death without joining him in his capacity as a co-

guardian.

¶ 8. In July 2023, the estate filed a motion in limine asking the court to exclude

evidence of any claim of negligence by father as co-guardian and requested that the jury not be

instructed on that issue at trial. The estate argued that contributory negligence did not apply

because the estate, through its administrator, brought suit as opposed to father filing in his

individual capacity. It also asserted that any issue related to comparative negligence of father

should be stricken because “[a]ny judgment entered for plaintiff would be for the estate.” See

14 V.S.A. § 1492(c).

3 ¶ 9. Procedurally, the court treated the motion in limine as a motion to strike the

affirmative defense of comparative negligence. It noted that the period within which the estate

could have moved to strike an affirmative defense had passed but exercised its discretion to

address the merits of whether the comparative negligence defense should be stricken from the

case. The court denied the motion because there were disputed questions of both fact and law.

The court concluded there were disputed facts about “the extent to which plaintiff was involved”

in decedent’s healthcare and disputed questions of law about whether father owed a duty to

decedent and had breached that duty.2 The court also noted whether father could be held

personally liable, despite only being named in the action as administrator for the estate,

remained in dispute and that “any analysis will likely depend on the facts elicited at trial.” In

doing so, the court rejected “plaintiff’s” request to strike the affirmative defense of contributory

negligence as a matter of law.

¶ 10. Following jury draw in May 2024, the estate settled with Heartbeet. After a six-

day trial, the jury entered a verdict for defendant. The estate timely appealed to this Court.

III. Discussion

A. Comparative Negligence

¶ 11. On appeal, the estate first claims that the trial court erred by denying its pretrial

motion to strike the affirmative defense of comparative negligence. We agree the trial court

committed error in its analysis by conflating the identity of the “plaintiff,” the administrator of

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