Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 1061 (2026)

✓ current as of May 2026
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Subchapter 007 : STALKING

(Cite as: 13 V.S.A. § 1061)
Notes of Decisions
Cited in 17 cases (2 in the last 5 years), 1998–2025 · leading case: State v. Hinchliffe, 2009 VT 111 (Vt. 2009).
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State v. Hinchliffe, 2009 VT 111 (Vt. 2009). · cites it 6× “In this case, the State’s theory was that defendant’s course of conduct was “harassing,” which is defined in the statute as: actions directed at a specific person, or a member of the person’s family, which would cause a reasonable person to fear unlawful sexual conduct, unlawful…”
C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). · cites it 5× “Compare 12 V.S.A. § 5131(6) with 13 V.S.A. § 1061(2), (4).”
State of Vermont v. Christian J. Noll, 199 A.3d 1054 (Vt. 2018). · cites it 4× “4 In 2016, the Legislature amended several definitions in the stalking statute effective July 1, 2016. 2015, No. 162 (Adj. Sess.), § 5.”
State v. Waters, 2013 VT 109 (Vt. 2013). · cites it 3× “13 V.S.A. § 1061(4). The statute prohibiting disturbing the peace by electronic communication does not define harassment, but states that “[a]n intent to terrify, threaten, harass or annoy may be inferred by the trier of fact from the use of obscene, lewd, lascivious or indecent…”
Nicholson v. State, 963 N.E.2d 1096 (Ind. 2012). “§ 16-3-1700 (2011); Vt. Stat. Ann. tit. 13 § 1061 (2010). 3 .”
State v. Prior, 917 A.2d 466 (Vt. 2007). · cites it 3× “The statute, at the time of the offenses, defined “following” as “maintaining over a period of time a visual or physical proximity to another person in such manner as would cause a reasonable person to have a fear of unlawful sexual conduct, unlawful restraint, bodily injury, or…”
State v. Ellis, 2009 VT 74 (Vt. 2009). “The term “stalk” is defined in 13 V.S.A. § 1061(1) and contains three elements, two of which are defined in the alternative.”
State v. Malshuk, 2004 VT 54 (Vt. 2004). “” 13 V.S.A. § 1061(1)(B). Similarly, it would be possible to follow someone without entering the buffer zone and to enter the buffer zone without following.”
State v. van Aelstyn, 2007 VT 6 (Vt. 2007). · cites it 2× “83, § 4 (amending definition of “stalk” in 13 V.S.A. § 1061); 1 V.S.A. § 212 (providing that laws take effect on July 1 following enactment unless otherwise provided).”
In re Hoch, 2013 VT 83 (Vt. 2013). · cites it 3× “” 13 V.S.A. § 1061(1)(B) (1993). The current version, as amended in 2005, defines stalking as a course of conduct described above that “would cause a reasonable person to fear for his or her physical safety or would cause a reasonable person substantial emotional distress.”
State v. Waters, 195 Vt. 233 (Vt. 2013). · cites it 3× “13 V.S.A. § 1061(4). The statute prohibiting disturbing the peace by electronic communication does not define harassment, but states that “[a]n intent to terrify, threaten, harass or annoy may be inferred by the trier of fact from the use of obscene, lewd, lascivious or indecent…”
State v. van Aelstyn, 181 Vt. 274 (Vt. 2007). “In July 2005, 13 V.S.A. § 1061 was amended: the definition of "stalk," which had prohibited conduct that "causes the person to fear for his or her physical safety," a subjective test, was redefined to include only conduct that "would cause a reasonable person to fear for his or…”
Show all 17 citing cases →
— Vt. Stat. Ann. tit. 13, § 1061(1) — 5 cases
State v. Hinchliffe, 2009 VT 111 (Vt. 2009). “In this case, the State’s theory was that defendant’s course of conduct was “harassing,” which is defined in the statute as: actions directed at a specific person, or a member of the person’s family, which would cause a reasonable person to fear unlawful sexual conduct, unlawful…”
State of Vermont v. Christian J. Noll, 199 A.3d 1054 (Vt. 2018). “4 In 2016, the Legislature amended several definitions in the stalking statute effective July 1, 2016. 2015, No. 162 (Adj. Sess.), § 5.”
C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). “Compare 12 V.S.A. § 5131(6) with 13 V.S.A. § 1061(2), (4).”
State v. Ellis, 2009 VT 74 (Vt. 2009). “The term “stalk” is defined in 13 V.S.A. § 1061(1) and contains three elements, two of which are defined in the alternative.”
State v. Prior, 917 A.2d 466 (Vt. 2007). “The statute, at the time of the offenses, defined “following” as “maintaining over a period of time a visual or physical proximity to another person in such manner as would cause a reasonable person to have a fear of unlawful sexual conduct, unlawful restraint, bodily injury, or…”
— Vt. Stat. Ann. tit. 13, § 1061(1)(B) — 3 cases
State v. Hinchliffe, 2009 VT 111 (Vt. 2009). “In this case, the State’s theory was that defendant’s course of conduct was “harassing,” which is defined in the statute as: actions directed at a specific person, or a member of the person’s family, which would cause a reasonable person to fear unlawful sexual conduct, unlawful…”
State v. Malshuk, 2004 VT 54 (Vt. 2004). “” 13 V.S.A. § 1061(1)(B). Similarly, it would be possible to follow someone without entering the buffer zone and to enter the buffer zone without following.”
In re Hoch, 2013 VT 83 (Vt. 2013). “” 13 V.S.A. § 1061(1)(B) (1993). The current version, as amended in 2005, defines stalking as a course of conduct described above that “would cause a reasonable person to fear for his or her physical safety or would cause a reasonable person substantial emotional distress.”
— Vt. Stat. Ann. tit. 13, § 1061(2) — 1 case
C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). “Compare 12 V.S.A. § 5131(6) with 13 V.S.A. § 1061(2), (4).”
— Vt. Stat. Ann. tit. 13, § 1061(3) — 2 cases
State of Vermont v. Christian J. Noll, 199 A.3d 1054 (Vt. 2018). “4 In 2016, the Legislature amended several definitions in the stalking statute effective July 1, 2016. 2015, No. 162 (Adj. Sess.), § 5.”
State v. Prior, 917 A.2d 466 (Vt. 2007). “The statute, at the time of the offenses, defined “following” as “maintaining over a period of time a visual or physical proximity to another person in such manner as would cause a reasonable person to have a fear of unlawful sexual conduct, unlawful restraint, bodily injury, or…”
— Vt. Stat. Ann. tit. 13, § 1061(4) — 5 cases
State v. Hinchliffe, 2009 VT 111 (Vt. 2009). “In this case, the State’s theory was that defendant’s course of conduct was “harassing,” which is defined in the statute as: actions directed at a specific person, or a member of the person’s family, which would cause a reasonable person to fear unlawful sexual conduct, unlawful…”
C. Paige Hinkson v. Stuart Stevens, 2020 VT 69 (Vt. 2020). “Compare 12 V.S.A. § 5131(6) with 13 V.S.A. § 1061(2), (4).”
State v. Waters, 2013 VT 109 (Vt. 2013). “13 V.S.A. § 1061(4). The statute prohibiting disturbing the peace by electronic communication does not define harassment, but states that “[a]n intent to terrify, threaten, harass or annoy may be inferred by the trier of fact from the use of obscene, lewd, lascivious or indecent…”
State v. Waters, 195 Vt. 233 (Vt. 2013). “13 V.S.A. § 1061(4). The statute prohibiting disturbing the peace by electronic communication does not define harassment, but states that “[a]n intent to terrify, threaten, harass or annoy may be inferred by the trier of fact from the use of obscene, lewd, lascivious or indecent…”
State v. Premo, 719 A.2d 398 (Vt. 1998).
— Vt. Stat. Ann. tit. 13, § 1061(5) — 1 case
In re Hoch, 2013 VT 83 (Vt. 2013). “” 13 V.S.A. § 1061(1)(B) (1993). The current version, as amended in 2005, defines stalking as a course of conduct described above that “would cause a reasonable person to fear for his or her physical safety or would cause a reasonable person substantial emotional distress.”
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