Vt. Stat. Ann. » Title 12 Chapter 61
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 1612 (2026)

✓ current as of May 2026
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Subchapter 001 : QUALIFICATIONS, PRIVILEGES, AND CREDIBILITY

(Cite as: 12 V.S.A. § 1612)
Notes of Decisions
Cited in 40 cases (2 in the last 5 years), 1976–2024 · leading case: Carole Kuligoski, Individually & On Behalf of Michael J. Kuligoski, & Mark Kuligoski & James Kuligoski v. Brattleboro Retreat & Ne. Kingdom Human Servs., 2016 VT 54A (Vt. 2016).
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Carole Kuligoski, Individually & On Behalf of Michael J. Kuligoski, & Mark Kuligoski & James Kuligoski v. Brattleboro Retreat & Ne. Kingdom Human Servs., 2016 VT 54A (Vt. 2016). · cites it 7× “First, while it is true that 12 V.S.A. § 1612 and the more comprehensive Vermont Rule of Evidence 503 prevent physicians from disclosing health information or history, the statute codifies an evidentiary privilege, thus limiting its application to judicial proceedings.”
Mattison v. Poulen, 353 A.2d 327 (Vt. 1976). · cites it 10× “The plaintiff states that the general questions of law presented here are whether 12 V.S.A. § 1612 applies not only to the physician disclosing information about the patient but also: (1) whether or not the physician’s reports to the patient are privileged; (2) whether or not…”
State v. Welch, 624 A.2d 1105 (Vt. 1992). · cites it 4× “Neither the statute, 12 V.S.A. § 1612(a), nor the evidentiary rule, V.”
Elizabeth Lawson v. Patricia Halpern-Reiss & Cent. Vermont Med. Ctr., 212 A.3d 1213 (Vt. 2019). · cites it 2× “In opposing summary judgment, plaintiff noted that the vast majority of jurisdictions have recognized a private right of action for damages resulting from the disclosure of information obtained during medical treatment. She argued that there were disputed material facts…”
State v. Valley, 571 A.2d 579 (Vt. 1989). · cites it 4× “503(b) (based on 12 V.S.A. § 1612). Defendant alleges that the information provided to the state hospital doctors and social worker came within the privilege and cannot be used by the State as part of its proof that defendant was sane at the time of the crime.”
State v. Lapham, 377 A.2d 249 (Vt. 1977). · cites it 3× “2d 18 (1971) that the physician-patient privilege does not apply is limited to that factual situation of court-ordered examinations.) See also 13 V.S.”
Carole Kuligoski, Individually & On Behalf of Michael J. Kuligoski, Mark Kuligoski & James Kuligoski v. Brattleboro Retreat & Ne. Kingdom Human Servs., 2016 VT 54 (Vt. 2016). · cites it 4× “§ 1612 and the more comprehensive Vermont Rule of Evidence 503 prevent physicians from disclosing health information or history, the statute codifies an evidentiary privilege, thus limiting its application to judicial proceedings. As such, it does not require the Retreat to…”
State v. Wright, 581 A.2d 720 (Vt. 1989). · cites it 3× “Defendant contends that 12 V.S.A. § 1612 does not bar disclosure of the records in this case, on the ground that V.”
State v. Comeaux, 818 S.W.2d 46 (Tex. Crim. App. 1991). · cites it 2× “12 V.S.A. § 1612(a). In Raymond , the court found that it was error to admit a nurse's statement that she smelled alcohol on the breath of a defendant charged with driving while intoxicated, as that information was privileged within the statute.”
State v. Raymond, 431 A.2d 453 (Vt. 1981). · cites it 4× “We held: “The physician-patient privilege in this jurisdiction, codified under 12 V.S.A. § 1612, prohibits a physician from disclosing any information acquired while attending his patient unless there is a waiver either by the patient or by express provision of law.”
State v. Parker, 545 A.2d 512 (Vt. 1988). · cites it 2× “Defendant argues that the testimony violated his patient’s privilege under 12 V.S.A. § 1612(a). In 1982 defendant’s wife referred their daughter to Dr.”
Peck v. Counseling Serv. of Addison Cnty., Inc., 499 A.2d 422 (Vt. 1985). · cites it 2× “" Stone, The Tarasoff Decisions: Suing Psychotherapists to Safeguard Society, supra, 90 Harv.”
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— Vt. Stat. Ann. tit. 12, § 1612(a) — 18 cases
Carole Kuligoski, Individually & On Behalf of Michael J. Kuligoski, & Mark Kuligoski & James Kuligoski v. Brattleboro Retreat & Ne. Kingdom Human Servs., 2016 VT 54A (Vt. 2016). “First, while it is true that 12 V.S.A. § 1612 and the more comprehensive Vermont Rule of Evidence 503 prevent physicians from disclosing health information or history, the statute codifies an evidentiary privilege, thus limiting its application to judicial proceedings.”
State v. Welch, 624 A.2d 1105 (Vt. 1992). “Neither the statute, 12 V.S.A. § 1612(a), nor the evidentiary rule, V.”
State v. Comeaux, 818 S.W.2d 46 (Tex. Crim. App. 1991). “12 V.S.A. § 1612(a). In Raymond , the court found that it was error to admit a nurse's statement that she smelled alcohol on the breath of a defendant charged with driving while intoxicated, as that information was privileged within the statute.”
Carole Kuligoski, Individually & On Behalf of Michael J. Kuligoski, Mark Kuligoski & James Kuligoski v. Brattleboro Retreat & Ne. Kingdom Human Servs., 2016 VT 54 (Vt. 2016). “§ 1612 and the more comprehensive Vermont Rule of Evidence 503 prevent physicians from disclosing health information or history, the statute codifies an evidentiary privilege, thus limiting its application to judicial proceedings. As such, it does not require the Retreat to…”
State v. Parker, 545 A.2d 512 (Vt. 1988). “Defendant argues that the testimony violated his patient’s privilege under 12 V.S.A. § 1612(a). In 1982 defendant’s wife referred their daughter to Dr.”
— Vt. Stat. Ann. tit. 12, § 1612(c) — 1 case
State v. Wright, 581 A.2d 720 (Vt. 1989). “Defendant contends that 12 V.S.A. § 1612 does not bar disclosure of the records in this case, on the ground that V.”
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