Kingsland Bay School, Inc. v. Town of Middlebury

In Kingsland Bay School, Inc. v. Town of Middlebury, 153 Vt. 201, 569 A.2d 496 (1989), the Court found that a nonprofit corporation which operates a group home in Middlebury for teenagers experiencing social and emotional difficulties was tax exempt under 3802(4). While we observed that the home provided its services without "any other limitation except for the capacity of its facilities," the Court ultimately applied the New York Institute definition of definite class of persons to examine the home's beneficiaries themselves and determined that because "troubled adolescents do not become residents of Kingsland as a result of any voluntary action or judgment on their part" they were an indefinite class of persons. Id. at 204, 569 A.2d at 498.