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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 1664 (2026)

✓ current as of May 2026
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Subchapter 004 : IMMUNITIES

(Cite as: 12 V.S.A. § 1664)
Notes of Decisions
Cited in 16 cases, 1984–2020 · leading case: State v. Welch, 624 A.2d 1105 (Vt. 1992).
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State v. Welch, 624 A.2d 1105 (Vt. 1992). · cites it 6× “In addition, she argues that Robinson was acting on behalf of the State when he initiated the interview, and therefore, she is immune pursuant to 12 V.S.A. § 1664. The rule in Garrity and defendant's signature on the "Employee Warning" form foreclose the use of her statements or…”
State v. Allard, 708 A.2d 1332 (Vt. 1997). · cites it 6× “12 V.S.A. § 1664. Unlike the earlier statute, the current law no longer provides transactional immunity to the witness.”
State v. Hamlin, 499 A.2d 45 (Vt. 1985). · cites it 2× “The State argues that it failed to call the companion as a witness and refused to grant him immunity under 12 V.S.A. § 1664 because, (1) the Attorney General was, at that time, investigating the possibility of perjury charges against him (he was, by then, sixteen years of age),…”
State v. Couture, 502 A.2d 846 (Vt. 1985). · cites it 3× “Neither 12 V.S.A. § 1664, the Pennsylvania cases cited by the State, nor Baxter v.”
State v. Briggs, 568 A.2d 779 (Vt. 1989). · cites it 3× “Casey were within the parameters of the state’s attorney’s discretion under 12 V.S.A. § 1664. See State v. Hamlin, 146 Vt.”
State v. Foy, 475 A.2d 219 (Vt. 1984). · cites it 2× “12 V.S.A. § 1664. He maintained that it was necessary because, in order to exculpate defendant, the witness would have to incriminate himself.”
Commonwealth v. Swinehart, 664 A.2d 957 (Pa. 1995). “§ 23A-14-29; Vt.Stat.Ann. tit. 12 § 1664; and, Wis.Stat.”
State v. David Gates, 2020 VT 21 (Vt. 2020). · cites it 3× “Defendant submits that, despite the language in 12 V.S.A. § 1664, we should look to case law from other jurisdictions holding that the trial court may grant immunity to a defense witness in the rare instance that it is necessary.”
State v. Haner, 928 A.2d 518 (Vt. 2007). · cites it 3× “While we have recognized exceptions to this statutory rule, they are few and limited in scope so as not to disrupt the separation of powers inherent in the Legislature's exclusive grant of authority to the Attorney General and state's attorneys.”
State v. Chambers, 477 A.2d 974 (Vt. 1984). “One of the participants (hereinafter “witness”) was granted full immunity by the State, 12 V.S.A. § 1664, and testified against defendant at trial.”
State v. Cate, 683 A.2d 1010 (Vt. 1996). “See 12 V.S.A. § 1664(a) (“no testimony or other information compelled under the order, or any information directly or indirectly derived from such testimony or other information, may be used for any purpose, including impeachment and cross-examination, .”
State v. Davis, 2010 VT 9 (Vt. 2010). · cites it 3× “The witness renewed his motion to quash, arguing that, in light of his deposition testimony, it was clear the State was only putting him on the stand “either to tiy to extract perjury or to impeach him,” and, as such, the State could no longer meet the necessity standard under…”
Show all 16 citing cases →
— Vt. Stat. Ann. tit. 12, § 1664(a) — 5 cases
State v. Allard, 708 A.2d 1332 (Vt. 1997). “12 V.S.A. § 1664. Unlike the earlier statute, the current law no longer provides transactional immunity to the witness.”
State v. Welch, 624 A.2d 1105 (Vt. 1992). “In addition, she argues that Robinson was acting on behalf of the State when he initiated the interview, and therefore, she is immune pursuant to 12 V.S.A. § 1664. The rule in Garrity and defendant's signature on the "Employee Warning" form foreclose the use of her statements or…”
State v. Briggs, 568 A.2d 779 (Vt. 1989). “Casey were within the parameters of the state’s attorney’s discretion under 12 V.S.A. § 1664. See State v. Hamlin, 146 Vt.”
State v. Cate, 683 A.2d 1010 (Vt. 1996). “See 12 V.S.A. § 1664(a) (“no testimony or other information compelled under the order, or any information directly or indirectly derived from such testimony or other information, may be used for any purpose, including impeachment and cross-examination, .”
State v. Neumann, 2007 VT 123 (Vt. 2007).
— Vt. Stat. Ann. tit. 12, § 1664(b) — 1 case
State v. David Gates, 2020 VT 21 (Vt. 2020). “Defendant submits that, despite the language in 12 V.S.A. § 1664, we should look to case law from other jurisdictions holding that the trial court may grant immunity to a defense witness in the rare instance that it is necessary.”
— Vt. Stat. Ann. tit. 12, § 1664(c) — 1 case
State v. Davis, 2010 VT 9 (Vt. 2010). “The witness renewed his motion to quash, arguing that, in light of his deposition testimony, it was clear the State was only putting him on the stand “either to tiy to extract perjury or to impeach him,” and, as such, the State could no longer meet the necessity standard under…”
— Vt. Stat. Ann. tit. 12, § 1664(c)(1) — 1 case
State v. Davis, 2010 VT 9 (Vt. 2010). “The witness renewed his motion to quash, arguing that, in light of his deposition testimony, it was clear the State was only putting him on the stand “either to tiy to extract perjury or to impeach him,” and, as such, the State could no longer meet the necessity standard under…”
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