What did the court decide in Hilder v. St. Peter?
Answered for: Vermont
Additionally, we hold that when the landlord is notified of the defect but fails to repair it within a reasonable amount of time, and the tenant subsequently repairs the defect, the tenant may deduct the expense of the repair from future rent.
Vermont's Supreme Court adopted the implied warranty of habitability, allowed repair-and-deduct, and held punitive damages may be available in an appropriate case.
This answer is true in Vermont and nowhere else on this site. Another jurisdiction is another answer, or an honest gap: see what has been read for Vermont.