Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 2022 (2026)

✓ current as of May 2026

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(Cite as: 13 V.S.A. § 2022)

§ 2022. Bad checks

A person who issues or passes a check or similar sight order for the payment of money, knowing that it will not be honored by the drawee, shall be imprisoned for not more than one year or fined not more than $1,000.00, or both. The court shall order restitution in the amount of the check or order, together with a service charge not to exceed $5.00, if it is established that the defendant has the ability to pay. For the purposes of this section, it may be inferred that the issuer knew that the check or order, other than a post-dated check or order, would not be paid if:

(1) the issuer had no account with the drawee at the time the check or order was issued; or

(2) the issuer had insufficient funds with the drawee at the time the check or order was issued or presented for payment, and

(A) the check or order was presented to the drawee for payment not more than 30 days after the date of issuance; and

(B) payment was refused by the drawee for reasons other than seizure or attachment of the issuer’s funds by order of a court or authorized governmental agency; and

(C) the issuer or a person acting in his or her behalf failed to make full satisfaction of the amount of the check or order within 10 days after receiving notice of its dishonor by the drawee. (Added 1971, No. 254 (Adj. Sess.), § 3, eff. April 11, 1972; amended 1981, No. 232 (Adj. Sess.), § 1, eff. May 6, 1982.)

Notes of Decisions

Cited in 8 cases, 1978–2009 · leading case: State v. McBurney, 484 A.2d 926 (Vt. 1984).

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State v. McBurney, 484 A.2d 926 (Vt. 1984). · cites it 8× “Defendants appeal their convictions for issuing a bad check in violation of 13 V.S.A. § 2022. The cases were consolidated for trial, and guilty verdicts were returned against both defendants.”

Pickett v. Quinn (In Re Pickett), 321 B.R. 663 (Bankr. D. Vt. 2005). · cites it 5× “On or about November 12, 2002, the Defendant filed an Information charging the Plaintiff with nine (9) counts of violations of 13 V.S.A. § 2022 (“Bad Checks”)(the “First Information”).”

State v. Foley, 443 A.2d 452 (Vt. 1982). · cites it 4× “The defendant moved to dismiss on the ground that the bad check statute, 13 V.S.A. § 2022, had impliedly repealed the false pretenses statute for cases involving a theft by check.”

State v. North, 2009 VT 40 (Vt. 2009). · cites it 2× “§ 2002 and passing bad checks in violation of 13 V.S.A. § 2022. As defendant was being led from the courtroom, the following exchange occurred: DEFENDANT: Go fuck yourself, Your Honor.”

State v. Allen, 507 A.2d 975 (Vt. 1986). · cites it 2× “§ 2002 and not with the crime of passing a bad check under 13 V.S.A. § 2022. The statute creates and defines the offense.”

Dennison v. Davis (In Re Dennison), 321 B.R. 378 (Bankr. D. Conn. 2005). “) and that on or about August 24, 2004, Davis filed criminal charges, pursuant to Vt. Stat. Ann. tit. 13 § 2022, 1 against the debtor for issuing “bad checks.”

Commonwealth v. Goren, 893 N.E.2d 786 (Mass. App. Ct. 2008). “§ 22-30A-24 (2006); Vt. Stat. Ann. tit. 13, § 2022 (1998). As noted earlier, Rhode Island does not have a bad check statute.”

State v. Kelley, 394 A.2d 1125 (Vt. 1978). “Defendant was convicted of issuing a check knowing he had insufficient funds, in violation of 13 V.S.A. § 2022. He appeals his conviction because of the trial court’s refusal to compel the attendance of out-of-state witnesses in his behalf, under 13 V.”

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