Vermont Statutes Annotated
Vt. Stat. Ann. tit. 13, § 1026 (2026)
Disorderly conduct
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Subchapter 004 : OTHER DISTURBANCES OF THE PEACE
(Cite as: 13 V.S.A. § 1026)-
§ 1026. Disorderly conduct
(a) A person is guilty of disorderly conduct if the person, with intent to cause public inconvenience or annoyance, or recklessly creates a risk thereof:
(1) engages in fighting or in violent, tumultuous, or threatening behavior;
(2) makes unreasonable noise;
(3) in a public place, uses abusive or obscene language;
(4) without lawful authority, disturbs any lawful assembly or meeting of persons; or
(5) obstructs vehicular or pedestrian traffic.
(b) A person who is convicted of disorderly conduct shall be imprisoned for not more than 60 days or fined not more than $500.00, or both. A person who is convicted of a second or subsequent offense under this section shall be imprisoned for not more than 120 days or fined not more than $1,000.00, or both.
(c) As used in this section:
(1) “Disturbs any lawful assembly or meeting of persons” means conduct that substantially impairs the effective conduct of an assembly or meeting, including conduct that:
(A) causes an assembly or meeting to terminate prematurely; or
(B) consists of numerous and sustained efforts to disrupt an assembly or meeting after being asked to desist.
(2) “Meeting” includes a meeting of a public body, as those terms are defined in 1 V.S.A. § 310. (Amended 1971, No. 222 (Adj. Sess.), § 5, eff. April 5, 1972; 2013, No. 150 (Adj. Sess.), § 3; 2025, No. 51, § 5, eff. June 9, 2025.)
Notes of Decisions
Cited in 48
cases (9 in the last 5 years), 1973–2026 · leading case: State v. William Schenk, 2018 VT 45, 190 A.3d 820.
State v. William Schenk, 2018 VT 45, 190 A.3d 820. “…ante, ¶ 26-27. The private interest in freedom from targeted threats may be amply protected by other statutes besides 13 V.S.A. § 1026. See 13 V.S.A. §§ 1026a, § 1027, § 1702. In fact, these other statutory provisions are arguably far better suited than § 1026 to address…”
State v. Read, 680 A.2d 944 (Vt. 1996). “13 V.S.A. § 1026 (emphasis added). Defendant was charged with violating the emphasized provision of § 1026.”
State v. David Tracy, 2015 VT 111, 130 A.3d 196. “5 At the time of the charges and trial, this provision was at 13 V.S.A. § 1026(3). In 2014, the Legislature added subsection (b) to § 1026 and relettered the statute accordingly.”
State v. Albarelli, 2011 VT 24, 19 A.3d 130. “2d 944, 948 (1996); 13 V.S.A. § 1026; see, e.g., Conn. Gen. Stat.”
State v. Amsden, 2013 VT 51, 75 A.3d 612. “Defendant was charged with one count of disorderly-conduct in violation of 13 V.S.A. § 1026 and one count of cruelty to a child in violation of 13 V.”
State v. Cole, 554 A.2d 253 (Vt. 1988). “The main question in this case is whether the State proved sufficient facts to convict defendant, John Cole, of disorderly conduct in violation of 13 V.S.A. § 1026. The trial court found sufficient proof and submitted the case to the jury, which convicted defendant.”
State v. Lund, 475 A.2d 1055 (Vt. 1984). “In this regard, he points out that he was charged with violating 13 V.S.A. § 1026 (1), which states, in part, that: A person who, with intent to cause public inconvenience, or annoyance or recklessly creating a risk thereof: (1) Engages in fighting or in violent, tumultuous or…”
Long v. L'esperance, 701 A.2d 1048 (Vt. 1997). “Following his arrest by defendant Trooper EEsperanee on the charge of disorderly conduct, see 13 V.S.A. § 1026, plaintiff brought this action alleging unlawful arrest, false imprisonment, assault, battery, and intentional infliction of emotional distress.”
State v. Sanville, 2011 VT 34, 22 A.3d 450. “Contrary to the State’s position, we find no support that defendant’s acts could have given rise to a charge of disorderly conduct under 13 V.S.A. § 1026. See State v. Albarelli, 2011 VT 24, ¶ 9 , 189 Vt.”
State v. McDermott, 373 A.2d 510 (Vt. 1977). “We do not reach the defendants’ third contention that 13 V.S.A. § 1026 is unconstitutionally vague on its face.”
Sandra Baird & Jared Carter, 2016 VT 6, 136 A.3d 223. “Compare Burlington Ordinances §§ 21-46, 21-47 (defining and prohibiting “disorderly conduct” and “unlawful mischief’ respectively) with 13 V.S.A. §§ 1026, 3701 (same). The third violation *116 is substantially the same as another municipal violation.”
State v. Arbeitman, 313 A.2d 17 (Vt. 1973). “Such intentional obstruction is one form of disorderly conduct prohibited by 13 V.S.A. § 1026. The relevant portions of this section provide: A person who, with intent to cause public inconvenience, or annoyance .”
Vt. Stat. Ann. tit. 13, § 1026(1): 12 cases
State v. Albarelli, 2011 VT 24, 19 A.3d 130. “2d 944, 948 (1996); 13 V.S.A. § 1026; see, e.g., Conn. Gen. Stat.”
State v. Lund, 475 A.2d 1055 (Vt. 1984). “In this regard, he points out that he was charged with violating 13 V.S.A. § 1026 (1), which states, in part, that: A person who, with intent to cause public inconvenience, or annoyance or recklessly creating a risk thereof: (1) Engages in fighting or in violent, tumultuous or…”
State v. Read, 680 A.2d 944 (Vt. 1996). “13 V.S.A. § 1026 (emphasis added). Defendant was charged with violating the emphasized provision of § 1026.”
State v. Begins, 509 A.2d 1007 (Vt. 1986).
State v. Cole, 554 A.2d 253 (Vt. 1988). “The main question in this case is whether the State proved sufficient facts to convict defendant, John Cole, of disorderly conduct in violation of 13 V.S.A. § 1026. The trial court found sufficient proof and submitted the case to the jury, which convicted defendant.”
Vt. Stat. Ann. tit. 13, § 1026(2): 1 case
State v. McDermott, 373 A.2d 510 (Vt. 1977). “We do not reach the defendants’ third contention that 13 V.S.A. § 1026 is unconstitutionally vague on its face.”
Vt. Stat. Ann. tit. 13, § 1026(3): 9 cases
State v. Read, 680 A.2d 944 (Vt. 1996). “13 V.S.A. § 1026 (emphasis added). Defendant was charged with violating the emphasized provision of § 1026.”
State v. David Tracy, 2015 VT 111, 130 A.3d 196. “5 At the time of the charges and trial, this provision was at 13 V.S.A. § 1026(3). In 2014, the Legislature added subsection (b) to § 1026 and relettered the statute accordingly.”
State v. William Schenk, 2018 VT 45, 190 A.3d 820. “…ante, ¶ 26-27. The private interest in freedom from targeted threats may be amply protected by other statutes besides 13 V.S.A. § 1026. See 13 V.S.A. §§ 1026a, § 1027, § 1702. In fact, these other statutory provisions are arguably far better suited than § 1026 to address…”
State v. Elwell, 303 A.2d 134 (Vt. 1973).
Long v. L'esperance, 701 A.2d 1048 (Vt. 1997). “Following his arrest by defendant Trooper EEsperanee on the charge of disorderly conduct, see 13 V.S.A. § 1026, plaintiff brought this action alleging unlawful arrest, false imprisonment, assault, battery, and intentional infliction of emotional distress.”
Vt. Stat. Ann. tit. 13, § 1026(4): 2 cases
State v. Colby, 2009 VT 28, 972 A.2d 197.
State v. Colby, State v. Wardinski, No. 2007-317 (Vt. Mar. 13, 2009).
Vt. Stat. Ann. tit. 13, § 1026(5): 5 cases
State v. Read, 680 A.2d 944 (Vt. 1996). “13 V.S.A. § 1026 (emphasis added). Defendant was charged with violating the emphasized provision of § 1026.”
State v. Arbeitman, 313 A.2d 17 (Vt. 1973). “Such intentional obstruction is one form of disorderly conduct prohibited by 13 V.S.A. § 1026. The relevant portions of this section provide: A person who, with intent to cause public inconvenience, or annoyance .”
State v. Jackowski, 181 Vt. 73 (2006).
David Arbeitman v. Dist. Court of Vermont, 522 F.2d 1031 (2d Cir. 1975).
State v. Jackowski, 915 A.2d 767 (Vt. 2006).
Vt. Stat. Ann. tit. 13, § 1026(A)(1): 1 case
State v. Joseph A. Blanchard, 2021 VT 13, 256 A.3d 567.
Vt. Stat. Ann. tit. 13, § 1026(a): 2 cases
State v. Cameron Albarelli, 2016 VT 119, 159 A.3d 627.
State v. William Schenk, 2018 VT 45, 190 A.3d 820. “…ante, ¶ 26-27. The private interest in freedom from targeted threats may be amply protected by other statutes besides 13 V.S.A. § 1026. See 13 V.S.A. §§ 1026a, § 1027, § 1702. In fact, these other statutory provisions are arguably far better suited than § 1026 to address…”
Vt. Stat. Ann. tit. 13, § 1026(a)(1): 11 cases
State v. William Schenk, 2018 VT 45, 190 A.3d 820. “…ante, ¶ 26-27. The private interest in freedom from targeted threats may be amply protected by other statutes besides 13 V.S.A. § 1026. See 13 V.S.A. §§ 1026a, § 1027, § 1702. In fact, these other statutory provisions are arguably far better suited than § 1026 to address…”
State v. David Tracy, 2015 VT 111, 130 A.3d 196. “5 At the time of the charges and trial, this provision was at 13 V.S.A. § 1026(3). In 2014, the Legislature added subsection (b) to § 1026 and relettered the statute accordingly.”
State v. David G. Buckley, 2016 VT 59, 149 A.3d 928.
State v. Elizabeth MacFarland, 2021 VT 87, 275 A.3d 110.
State v. Michael Harwood, 2020 VT 65, 238 A.3d 661.
Vt. Stat. Ann. tit. 13, § 1026(a)(2): 1 case
State v. Treyez L. McEachin, 2019 VT 37.
Vt. Stat. Ann. tit. 13, § 1026(a)(3): 4 cases
State v. David Tracy, 2015 VT 111, 130 A.3d 196. “5 At the time of the charges and trial, this provision was at 13 V.S.A. § 1026(3). In 2014, the Legislature added subsection (b) to § 1026 and relettered the statute accordingly.”
State v. William Schenk, 2018 VT 45, 190 A.3d 820. “…ante, ¶ 26-27. The private interest in freedom from targeted threats may be amply protected by other statutes besides 13 V.S.A. § 1026. See 13 V.S.A. §§ 1026a, § 1027, § 1702. In fact, these other statutory provisions are arguably far better suited than § 1026 to address…”
Billewicz v. Humphries, No. 24-cv-4685 (Vt. Super. Ct. Dec. 15, 2025).
Johnathan Billewicz v. William Humphries, No. 26-AP-007 (Vt. June 5, 2026).
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