Vt. Stat. Ann. » Title 13 Chapter 1
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 11 (2026)

Habitual criminals

✓ current as of May 2026
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(Cite as: 13 V.S.A. § 11)
Notes of Decisions
Cited in 60 cases (11 in the last 5 years), 1964–2025 · leading case: State v. Pellerin, 2010 VT 26 (Vt. 2010).
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State v. Pellerin, 2010 VT 26 (Vt. 2010). · cites it 25× “The State argues that, because defendant was given notice of the possibility of life imprisonment under Vermont's habitual offender statute, 13 V.S.A. § 11, defendant faces charges punishable by life imprisonment.”
State v. Ingerson, 2004 VT 36 (Vt. 2004). · cites it 9× “Defendant was convicted of burglarizing Walker’s Restaurant in Brattleboro, Vermont and received an enhanced sentence of twenty to thirty years of imprisonment as a habitual offender under 13 V.S.A. § 11. Defendant appeals both the conviction and sentence, claiming that (1) he…”
State v. Rideout, 933 A.2d 706 (Vt. 2007). · cites it 9× “If defendant’s four felony convictions from 1979 had not been counted, he would have had only two prior felonies, and could not have been sentenced as a habitual criminal.”
State v. Carpenter, 2013 VT 28 (Vt. 2013). · cites it 8× “Section 11 generally provides that a person already convicted of three felonies may, upon a fourth or subsequent felony conviction, be sentenced “to imprisonment up to and including life.”
State v. Angelucci, 405 A.2d 33 (Vt. 1979). · cites it 5× “He was also charged under the habitual offender statute, 13 V.S.A. § 11. This issue was presented to the jury and resulted in conviction after completion of the original felony *276 trial.”
State v. Brillon, 2008 VT 35 (Vt. 2008). · cites it 2× “See 13 V.S.A. § 11. ¶ 10. Three days after the July 27, 2001 incident, the district court issued a no-bail order, and defendant remained incarcerated.”
State v. Joshua Boyer, 2021 VT 19 (Vt. 2021). · cites it 3× “77, § 6. Presumably in response, on October 16, 2019, the aggravated assault charge was amended to first-degree aggravated domestic assault under 13 V.”
State v. Brillon, 2010 VT 25 (Vt. 2010). · cites it 2× “See 13 V.S.A. § 11. ¶ 3. Following his arrest in July 2001, defendant was held on a no-bail order until his case was finally tried in June 2004.”
State v. Kasper, 404 A.2d 85 (Vt. 1979). · cites it 2× “Part B charged him with being an “habitual criminal” in violation of 13 V.S.A. § 11. The trial court, relying on the habitual criminal statute, sentenced the defendant to three life terms, one for each conviction.”
State v. Jonas, 792 P.2d 705 (Ariz. 1990). · cites it 2× “18 § 4224(h); with 3 priors, natural life, Vt. Stat. Ann. tit. 13 § 11; Virginia, 50 years, Va.”
State v. Beaudoin, 2008 VT 133 (Vt. 2008). · cites it 2× “13 V.S.A. § 11. After the jury reached a verdict on the two counts of lewd or lascivious conduct with a child, defendant waived his right to a jury trial on the habitual-offender charge.”
State v. Setien, 795 A.2d 1135 (Vt. 2002). · cites it 3× “§§ 9, 608, and as a habitual offender, 13 V.S.A. § 11, claiming that (1) he was denied his right to testify because the trial court ruled in limine that the State could impeach defendant with evidence of his past criminal convictions; (2) he was convicted of two crimes but…”
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