Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 2304 (2026)

✓ current as of May 2026
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(Cite as: 13 V.S.A. § 2304)
Notes of Decisions
Cited in 21 cases (1 in the last 5 years), 1966–2023 · leading case: State v. Valley, 571 A.2d 579 (Vt. 1989).
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State v. Valley, 571 A.2d 579 (Vt. 1989). · cites it 6× “After an autopsy, the medical examiner determined that the cause of the child's death was asphyxiation due to vomit in her air passages.”
United States v. Gomez-Leon, 545 F.3d 777 (9th Cir. 2008). · cites it 2× “§ 16-3-60 (offense called "involuntary manslaughter," but requires criminal negligence); Vt. Stat. Ann. tit. 13, § 2304 (offense called "manslaughter," but requires criminal negligence as interpreted by State v.”
State v. Brooks, 658 A.2d 22 (Vt. 1995). · cites it 2× “13 V.S.A. § 2304; State v. Stanislaw, 153 Vt.”
State v. Viens, 2009 VT 64 (Vt. 2009). · cites it 2× “13 V.S.A. §2304. On appeal, defendant claims that the trial court erred in instructing the jury and in denying defendant’s motions for a judgment of acquittal.”
State v. Forbes, 523 A.2d 1232 (Vt. 1987). · cites it 2× “The first alleged a violation of common law manslaughter (penalty provided by 13 V.S.A. § 2304); the second a violation of 13 V.”
Commonwealth v. Heck, 491 A.2d 212 (Pa. 1985). “2d 766 (1976)); Vt.Stat.Ann. tit. 13, § 2304 (1974 & Supp.”
State v. Kimmick, 2007 VT 45 (Vt. 2007). “In this case, however, where defendant's maximum sentence was set at the statutory maximum under 13 V.S.A. § 2304, accepting defendant's argument would require that the minimum sentence be reduced to keep the effective maximum and minimum terms different.”
State v. Melissa Robitille, 213 A.3d 437 (Vt. 2019). “¶ 13 ; see also 13 V.S.A. § 2304 (providing penalty for manslaughter).”
In Re Est. of Mahoney, 220 A.2d 475 (Vt. 1966). · cites it 2× “13 V.S.A. § 2304. The cause now before us is here on a direct appeal from the probate court.”
State v. Poirier, 458 A.2d 1109 (Vt. 1983). “This is an appeal by defendant from a jury verdict which found him guilty of four offenses: manslaughter (13 V.S.A. § 2304); driving under the influence with a fatal accident resulting (23 V.”
State v. Shabazz, 739 A.2d 666 (Vt. 1999). “See 13 V.S.A. § 2304; see also State v. Stanislaw, 153 Vt.”
State v. Beayon, 605 A.2d 527 (Vt. 1992). “§ 1091(c) is a criminal homicide statute which now imposes the same penalty as Vermont’s manslaughter statute, 13 V.S.A. § 2304. As we noted in Stanislaw , “[t]he legislature could not have intended to subject a person to a sentence of this duration without requiring the State…”
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