We review this legal question of statutory interpretation de novo. Chayer v. Ethan Allen, Inc., 2008 VT 45, ¶ 9, 183 Vt. 439, 954 A.2d 783. Our review is nondeferential and plenary. Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 4, 186 Vt. 97, 978 A.2d 33. ¶ 10.

The VSC has noted that the "capacity to sue or be sued exists only in persons in being, and not in those who are dead, . . . and so cannot be brought before the court." Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 6, 978 A.2d 33, 186 Vt. 97 (quoting Mortimore v. Bashore, 148 N.E. 317, 319 (1925)). Because a deceased person does not have the capacity to be sued, Defendant Hamlet is also DISMISSED.

See Comm. to Save the Bishop's House, Inc. v. Med. Ctr. Hosp. of Vt., Inc., 400 A.2d 1015, 1021 (Vt. 1979) ("This Court must presume that all language in a statute was drafted advisedly, and that the plain ordinary meaning of the language used was intended."); Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 4, 978 A.2d 33, 35 (in construing a statute, a court presumes that "'the Legislature intended the plain, ordinary meaning of [the] statute.'" (citation omitted)).

A cause of action for breach of contract accrues when the breach occurs . . . ." Benson v. MVP Health Plan, Inc., 2009 VT 186 ¶ 5, 978 A.2d 33, 35 (citations omitted).

Bushey v. Allstate Ins. Co., 670 A.2d 807, 809 (Vt. 1995). "An insurance company may challenge claims that are 'fairly debatable' and 'will be found liable only where it has intentionally denied (or failed to process or pay) a claim without a reasonable basis.'" Id., quoting Booska v. Hubbard Ins. Agency, Inc., 627 A.2d 333, 336 (Vt. 1993); accord Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 5, 978 A. 2d 33, 35 ("[A] cause of action against an insurance company for bad faith accrues when the company errs, unreasonably, in denying coverage."). According to the proposed SAC, Concord denied Littlefield's request to pay UIM benefits because of "causation issues."

Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 4, 186 Vt. 97, 978 A.2d 33. A. Oppression

Because a claim subject to § 5263 is one "maintained against the grantee of . . . lands in a tax collector's deed," it can accrue no earlier than the issuance of such deed following the expiration of the redemption period. See 32 V.S.A. § 5261 ("When the time for redemption has passed and the land is not redeemed, the collector . . . shall execute to the purchaser a deed, which shall convey to him or her a title against the person for whose tax it was sold . . . ."); see also Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 5, 186 Vt. 97, 978 A.2d 33 ("A cause of action does not accrue until each element of the cause of action exists."). Thus, if subject to § 5263, this cause of action would have accrued upon issuance of the deeds to the Town on April 1, 2015, and an action brought in March 2018 would fall within the then-existing three-year limitation period.

We review issues of statutory interpretation de novo. Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 4, 186 Vt. 97, 978 A.2d 33. When construing a statute, "[o]ur primary objective is to effectuate the intent of the Legislature."

"In cases of statutory interpretation, our review is nondeferential and plenary." Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 4, 186 Vt. 97, 978 A.2d 33. Our primary goal when interpreting a statute is to fulfill the intent of the Legislature.

"In cases of statutory interpretation, our review is nondeferential and plenary." Benson v. MVP Health Plan, Inc., 2009 VT 57, ¶ 4, 186 Vt. 97, 978 A.2d 33. Our primary goal when interpreting a statute is to fulfill the intent of the Legislature.