summary hearing (Vermont) · Go Syfert
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summary hearing in Vermont

9 Vermont opinions name it 1 courts 1971–1992 0 in the last five years

The cases below were cited by Vermont courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
State v. Dellvenerigreen
vt · 1969 · cited in 3 Vermont opinions naming this issue, 1971–1973
2 sentences

1972As we held in State v. Dellveneri, 128 Vt. 85, 88 , 258 A.2d 834 (1969), and McGarry v. Costello, 128 Vt. 234, 239 , 260 A.2d 402 (1969), the summary hearing is in the nature of an administrative proceeding and is the determination of a civil matter involving only the question of whether the defendant should have his license suspended for six months.

1972As we held in State v. Dellveneri, 128 Vt. 85, 88 , 258 A.2d 834 (1969), and McGarry v. Costello, 128 Vt. 234, 239 , 260 A.2d 402 (1969), the summary hearing is in the nature of an administrative proceeding and is the determination of a civil matter involving only the question of whether the defendant should have his license suspended for six months.

13
McGarry v. Costellogreen
vt · 1969 · cited in 2 Vermont opinions naming this issue, 1971–1972
2 sentences

1972As we held in State v. Dellveneri, 128 Vt. 85, 88 , 258 A.2d 834 (1969), and McGarry v. Costello, 128 Vt. 234, 239 , 260 A.2d 402 (1969), the summary hearing is in the nature of an administrative proceeding and is the determination of a civil matter involving only the question of whether the defendant should have his license suspended for six months.

1972As we held in State v. Dellveneri, 128 Vt. 85, 88 , 258 A.2d 834 (1969), and McGarry v. Costello, 128 Vt. 234, 239 , 260 A.2d 402 (1969), the summary hearing is in the nature of an administrative proceeding and is the determination of a civil matter involving only the question of whether the defendant should have his license suspended for six months.

12
Pfeil v. Rutland District Courtgreen
vt · 1986 · cited in 1 Vermont opinions naming this issue, 1989–1989
2 sentences

1989See Lynaugh, 148 Vt. at 126 , 530 A.2d at 557 ; Pfeil v. Rutland District Court, 147 Vt. 305, 307 , 515 A.2d 1052, 1054 (1986).

1989See Lynaugh, 148 Vt. at 126 , 530 A.2d at 557 ; Pfeil v. Rutland District Court, 147 Vt. 305, 307 , 515 A.2d 1052, 1054 (1986).

11
State v. Lynaughgreen
vt · 1987 · cited in 1 Vermont opinions naming this issue, 1989–1989
2 sentences

1989See Lynaugh, 148 Vt. at 126 , 530 A.2d at 557 ; Pfeil v. Rutland District Court, 147 Vt. 305, 307 , 515 A.2d 1052, 1054 (1986).

1989See Lynaugh, 148 Vt. at 126 , 530 A.2d at 557 ; Pfeil v. Rutland District Court, 147 Vt. 305, 307 , 515 A.2d 1052, 1054 (1986).

11
Pope v. United Statesgreen
scotus · 1968 · cited in 1 Vermont opinions naming this issue, 1973–1973
2 sentences

1973See also Pope v. United States, 392 U.S. 651 , 88 S.Ct. 2145 , 20 L.Ed.2d 1317 (1968).

1973See also Pope v. United States, 392 U.S. 651 , 88 S.Ct. 2145 , 20 L.Ed.2d 1317 (1968).

11
Powell v. Texasgreen
scotus · 1968 · cited in 1 Vermont opinions naming this issue, 1973–1973
1 sentence

1973See also Pope v. United States, 392 U.S. 651 , 88 S.Ct. 2145 , 20 L.Ed.2d 1317 (1968).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Vermont. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
State v. Mastaler green
vt · 1971
2 sentences

1973State v. Mastaler, 130 Vt. 44, 50 , 285 A.2d 776 (1971); State v. Dellveneri, 128 Vt. 85, 88 , 258 A.2d 834 (1969).

1972In the Mastaler case, supra, 285 A.2d at 782 , this Court held: “. . . it is necessary for the operator to select and submit to a test that is reasonably available if he is to avoid the effect of a summary hearing and the imminent danger of a suspension of his license for six months.” Given the choice of the reasonably available tests, blood, breath, or urine, the law required the defendant to submit to one of such tests and lacking this, it was tantamount to a refusal.

31971–1973
People v. Moore green
ill · 1990
2 sentences

1992The Illinois Supreme Court emphasized that these features were inconsistent with the application of issue preclusion, and that permitting such application would require officers to testify at the civil suspension hearings, resulting in a frustration of the purpose of the summary procedure. 138 Ill. 2d at 169-70 , 561 N.E.2d at 651-52 .

1992The Illinois Supreme Court emphasized that these features were inconsistent with the application of issue preclusion, and that permitting such application would require officers to testify at the civil suspension hearings, resulting in a frustration of the purpose of the summary procedure. 138 Ill. 2d at 169-70 , 561 N.E.2d at 651-52 .

11992–1992
State v. Welch green
vt · 1977
2 sentences

1979State v. Welch, 135 Vt. 316 , 376 A.2d 351 (1977).

1979State v. Welch, 135 Vt. 316 , 376 A.2d 351 (1977).

11979–1979
United States v. Jackson green
scotus · 1968
2 sentences

1973By conditioning the summary hearing in 23 V.S.A. § 1205 on the entry of the plea of not guilty, only after which, depending on the outcome of the hearing, does the accused suffer a six month operator's license suspension, this statute is brought within the constitutionally impermissible ambit of United States v. Jackson, 390 U.S. 570 , 88 S.Ct. 1209 , 20 L.Ed.2d 138 (1968).

1973By conditioning the summary hearing in 23 V.S.A. § 1205 on the entry of the plea of not guilty, only after which, depending on the outcome of the hearing, does the accused suffer a six month operator's license suspension, this statute is brought within the constitutionally impermissible ambit of United States v. Jackson, 390 U.S. 570 , 88 S.Ct. 1209 , 20 L.Ed.2d 138 (1968).

11973–1973
State v. Laplaca green
vt · 1966
2 sentences

1971State v. Laplaca, 126 Vt. 171, 174 , 224 A.2d 911 (1966).

1971State v. Laplaca, 126 Vt. 171, 174 , 224 A.2d 911 (1966).

11971–1971

Statutes the citing opinions construe

VT § Vt. Stat. Ann. tit. 23, § 1205 (9) VT § Vt. Stat. Ann. tit. 23, § 1201 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NJ 47 (1898–2025) NY 46 (1832–2026) PA 31 (1938–2025) CA 21 (1934–2026) TX 20 (1910–2025) LA 20 (1934–2012) WV 18 (1968–2011) OR 13 (1949–2019) IL 10 (1912–2025) MA 10 (1935–2013) MI 10 (1895–2023) VT 9 (1971–1992) OH 9 (1963–2025) IN 8 (1884–2019) WA 8 (1892–2025) OK 7 (1979–2022) FL 7 (1973–2014) GA 5 (1943–2018) ME 5 (1985–2023) WI 5 (1979–2023) NC 4 (1894–2025) IA 4 (1969–2023) MN 4 (1980–2005) DC 3 (1996–2003) ID 3 (1966–1996) MT 3 (1989–2013) VA 3 (1885–2000) MD 3 (1896–2021) MO 3 (1915–1990) UT 2 (2013–2024) CT 2 (1930–1992) MS 2 (1942–1963) AL 2 (1989–2005) KS 2 (1911–1919) CO 2 (2008–2008) AK 2 (1975–1993) KY 2 (1987–2019) AZ 2 (1986–1988)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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