Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 5131 (2026)

✓ current as of May 2026
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(Cite as: 12 V.S.A. § 5131)
Notes of Decisions
Cited in 27 cases (20 in the last 5 years), 2013–2026 · leading case: C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020).
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C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). · cites it 17× “that his conduct of (1) calling plaintiff’s cell phone repeatedly from a number with no caller ID, (2) sending three shipments of books addressed to her husband to the house she and her husband shared, including primarily books about rape, and (3) watching her in a coffee shop…”
Elizabeth Swett, Doug Earle, Gordon Stake v. Brian Gates, 2023 VT 26 (Vt. 2023). · cites it 3× “See 12 V.S.A. § 5131(6) (defining “stalk” as “to engage purposefully in a course of conduct directed at a specific person that the person engaging in the conduct knows or should know would cause a reasonable person to: (A) fear for his or her safety or the safety of a family…”
Ava Morton v. Mayah Young, 2023 VT 29 (Vt. 2023). · cites it 4× “Plaintiff argues that the decision below should be reversed because defendant made two or more threats that caused her substantial emotional distress and therefore engaged in a course of conduct sufficient to constitute stalking under 12 V.S.A. § 5131. Whether the trial court…”
Sean Beatty v. Kathryn Keough, 2022 VT 41 (Vt. 2022). · cites it 3× “We agree with defendant that the evidence does not support the trial court’s conclusion that she engaged in “two or more acts over a period of time, however short” as required by 12 V.S.A. § 5131(1)(A). We therefore reverse.”
Melissa L. Scheffler v. Raymond G. Harrington, 2020 VT 93 (Vt. 2020). · cites it 3× “The trial court issued the order because it concluded that defendant stalked plaintiff, within the meaning of 12 V.S.A. § 5131, by driving by her home on multiple occasions and honking his horn, which the court found constituted surveillance.”
Gail Haupt v. John Langlois, 2024 VT 3 (Vt. 2024). · cites it 4× “10 violence amount to threats under 12 V.S.A. § 5131. We therefore conclude that the court did not err in imposing a no-stalking order.”
Fox v. Fox, 2014 VT 100 (Vt. 2014). “In that order, the court made a finding that defendant had stalked plaintiff as defined in 12 V.S.A. § 5131(6). The court denied defendant’s motion to reconsider his motion to dismiss, and defendant appealed.”
Carrie McCool v. Joshua Macura, 2019 VT 85 (Vt. 2019). · cites it 2× “§ 1101(1)(D) (providing “[s]talking” as one of several definitions of abuse under RFA statute); 12 V.S.A. § 5131(6) (defining stalking as “to engage 8 The majority suggests that defendant engaged in an ill-conceived but otherwise relatively benign effort to retrieve his…”
Dugan v. Sorensen, 319 Neb. 326 (Neb. 2025). “Plaintiff testified, and the court found, that after striking plaintiff, defendant followed him out of the work building to the parking lot.”
Hartwell v. Schuetz (Vt. Super. Ct. 2026). · cites it 4× “Scheutz has never threatened her with physical harm, nor can the Court find that any of his actions constitute threats under 12 V.S.A. § 5131(1). While Hartwell may have found Scheutz’s emails and complaints “harassing,” no overt or implied threats of physical harm were…”
Timothy Dasler v. Jennifer Knapp (Vt. 2023). · cites it 3× “” 12 V.S.A. § 5131(1)(A). The definition applies “to acts conducted by the person directly or indirectly, and by any action, method, device, or means.”
Frank Venturella v. Sean Thompson (Vt. 2025). · cites it 3× “Next, plaintiff argues that the court erred in finding that he failed to prove that defendant engaged in two or more acts constituting a “course of conduct” within the meaning of 12 V.S.A. § 5131(1)(A). Though plaintiff contends that the court failed to appropriately consider…”
Show all 27 citing cases →
— Vt. Stat. Ann. tit. 12, § 5131(1) — 6 cases
C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). “that his conduct of (1) calling plaintiff’s cell phone repeatedly from a number with no caller ID, (2) sending three shipments of books addressed to her husband to the house she and her husband shared, including primarily books about rape, and (3) watching her in a coffee shop…”
Ava Morton v. Mayah Young, 2023 VT 29 (Vt. 2023). “Plaintiff argues that the decision below should be reversed because defendant made two or more threats that caused her substantial emotional distress and therefore engaged in a course of conduct sufficient to constitute stalking under 12 V.S.A. § 5131. Whether the trial court…”
Gail Haupt v. John Langlois, 2024 VT 3 (Vt. 2024). “10 violence amount to threats under 12 V.S.A. § 5131. We therefore conclude that the court did not err in imposing a no-stalking order.”
Brian Tomlinson v. Kathleen Lovell (Vt. 2025).
Hartwell v. Schuetz (Vt. Super. Ct. 2026). “Scheutz has never threatened her with physical harm, nor can the Court find that any of his actions constitute threats under 12 V.S.A. § 5131(1). While Hartwell may have found Scheutz’s emails and complaints “harassing,” no overt or implied threats of physical harm were…”
— Vt. Stat. Ann. tit. 12, § 5131(1)(A) — 7 cases
C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). “that his conduct of (1) calling plaintiff’s cell phone repeatedly from a number with no caller ID, (2) sending three shipments of books addressed to her husband to the house she and her husband shared, including primarily books about rape, and (3) watching her in a coffee shop…”
Sean Beatty v. Kathryn Keough, 2022 VT 41 (Vt. 2022). “We agree with defendant that the evidence does not support the trial court’s conclusion that she engaged in “two or more acts over a period of time, however short” as required by 12 V.S.A. § 5131(1)(A). We therefore reverse.”
Melissa L. Scheffler v. Raymond G. Harrington, 2020 VT 93 (Vt. 2020). “The trial court issued the order because it concluded that defendant stalked plaintiff, within the meaning of 12 V.S.A. § 5131, by driving by her home on multiple occasions and honking his horn, which the court found constituted surveillance.”
Gail Haupt v. John Langlois, 2024 VT 3 (Vt. 2024). “10 violence amount to threats under 12 V.S.A. § 5131. We therefore conclude that the court did not err in imposing a no-stalking order.”
Frank Venturella v. Sean Thompson (Vt. 2025). “Next, plaintiff argues that the court erred in finding that he failed to prove that defendant engaged in two or more acts constituting a “course of conduct” within the meaning of 12 V.S.A. § 5131(1)(A). Though plaintiff contends that the court failed to appropriately consider…”
— Vt. Stat. Ann. tit. 12, § 5131(1)(B) — 2 cases
Sean Beatty v. Kathryn Keough, 2022 VT 41 (Vt. 2022). “We agree with defendant that the evidence does not support the trial court’s conclusion that she engaged in “two or more acts over a period of time, however short” as required by 12 V.S.A. § 5131(1)(A). We therefore reverse.”
Gail Haupt v. John Langlois, 2024 VT 3 (Vt. 2024). “10 violence amount to threats under 12 V.S.A. § 5131. We therefore conclude that the court did not err in imposing a no-stalking order.”
— Vt. Stat. Ann. tit. 12, § 5131(5) — 1 case
Sonya Sprague v. Thomas Sprague (Vt. 2024).
— Vt. Stat. Ann. tit. 12, § 5131(6) — 17 cases
C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). “that his conduct of (1) calling plaintiff’s cell phone repeatedly from a number with no caller ID, (2) sending three shipments of books addressed to her husband to the house she and her husband shared, including primarily books about rape, and (3) watching her in a coffee shop…”
Elizabeth Swett, Doug Earle, Gordon Stake v. Brian Gates, 2023 VT 26 (Vt. 2023). “See 12 V.S.A. § 5131(6) (defining “stalk” as “to engage purposefully in a course of conduct directed at a specific person that the person engaging in the conduct knows or should know would cause a reasonable person to: (A) fear for his or her safety or the safety of a family…”
Fox v. Fox, 2014 VT 100 (Vt. 2014). “In that order, the court made a finding that defendant had stalked plaintiff as defined in 12 V.S.A. § 5131(6). The court denied defendant’s motion to reconsider his motion to dismiss, and defendant appealed.”
Ava Morton v. Mayah Young, 2023 VT 29 (Vt. 2023). “Plaintiff argues that the decision below should be reversed because defendant made two or more threats that caused her substantial emotional distress and therefore engaged in a course of conduct sufficient to constitute stalking under 12 V.S.A. § 5131. Whether the trial court…”
Carrie McCool v. Joshua Macura, 2019 VT 85 (Vt. 2019). “§ 1101(1)(D) (providing “[s]talking” as one of several definitions of abuse under RFA statute); 12 V.S.A. § 5131(6) (defining stalking as “to engage 8 The majority suggests that defendant engaged in an ill-conceived but otherwise relatively benign effort to retrieve his…”
— Vt. Stat. Ann. tit. 12, § 5131(6)(A) — 1 case
Carrie McCool v. Joshua Macura, 2019 VT 85 (Vt. 2019). “§ 1101(1)(D) (providing “[s]talking” as one of several definitions of abuse under RFA statute); 12 V.S.A. § 5131(6) (defining stalking as “to engage 8 The majority suggests that defendant engaged in an ill-conceived but otherwise relatively benign effort to retrieve his…”
— Vt. Stat. Ann. tit. 12, § 5131(6)(B) — 2 cases
C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). “that his conduct of (1) calling plaintiff’s cell phone repeatedly from a number with no caller ID, (2) sending three shipments of books addressed to her husband to the house she and her husband shared, including primarily books about rape, and (3) watching her in a coffee shop…”
Hartwell v. Schuetz (Vt. Super. Ct. 2026). “Scheutz has never threatened her with physical harm, nor can the Court find that any of his actions constitute threats under 12 V.S.A. § 5131(1). While Hartwell may have found Scheutz’s emails and complaints “harassing,” no overt or implied threats of physical harm were…”
— Vt. Stat. Ann. tit. 12, § 5131(6)(B)(ii) — 1 case
Melanie MacEachern v. Kurtis Mellett (Vt. 2026).
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