Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 2404 (2026)

✓ current as of May 2026
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(Cite as: 13 V.S.A. § 2404)
Notes of Decisions
Cited in 12 cases (1 in the last 5 years), 1995–2023 · leading case: United States v. Marlon Flores-Granados, 783 F.3d 487 (4th Cir. 2015).
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United States v. Marlon Flores-Granados, 783 F.3d 487 (4th Cir. 2015). · cites it 4× “§§ 76-5-301 , -302; Vt. Stat. Ann. tit. 13, §§ 2404 , 2405(a); Wash.”
State v. Carrasquillo, 795 A.2d 1141 (Vt. 2002). · cites it 3× “Defendant also argues on appeal that the evidence presented at trial was quantitatively insufficient, as a matter of law, to satisfy the “substantial period” element of Vermont’s kidnapping statute, 13 V.S.A. § 2404(3)(C). We affirm. Defendant Carrasquillo was an inmate at the…”
State v. Alexander, 795 A.2d 1248 (Vt. 2002). · cites it 2× “Finally, defendant contends the evidence was insufficient to establish the element of restraint under the kidnapping statute because the victim was not confined for a "substantial" period nor moved a "substantial" distance.”
State v. Goodhue, 2003 VT 85 (Vt. 2003). “” The State relied on the definition of “restrain” found in 13 V.S.A. §2404(3)(C): “‘Restrain’ means to restrict substantially the movement of another person without the person’s consent or other lawful authority by confining the restrained person for a substantial period either…”
State v. Petruccelli, 743 A.2d 1062 (Vt. 1999). · cites it 2× “If defendant is found to possess the same status as the father of a child born in wedlock, defendant argues he “necessarily qualifies” as a “lawful custodian” of the baby, pursuant to 13 V.S.A. § 2404(1) (lawful custodian is a “parent, guardian or other person responsible by…”
State v. Washington, 691 A.2d 583 (Vt. 1997). · cites it 2× “13 VS.A. § 2404(3) (“‘[r]estrain’ means to restrict substantially the movement of another person without the person’s consent or other lawful authority”).”
State v. Washington, 691 A.2d 583 (Vt. 1997). · cites it 2× “Defendant asserts the evidence was insufficient to support the kidnapping charge because it failed to establish the element of restraint, which requires some substantial movement or confinement without the victim's consent.”
State v. Lang, 664 A.2d 267 (Vt. 1995). “The term “restrain” means “to restrict substantially the movement of another person without the person’s consent .”
State v. Jones, 2011 VT 90 (Vt. 2011). “In Lang , as in this case, the defendant argued that the victims were not confined for a “substantial period” as required by 13 V.S.A. § 2404(3)(C). The temporal duration of the restraint was relevant but not to the exclusion of other qualitative factors.”
State v. O'Dell, 2007 VT 34 (Vt. 2007). “” 13 V.S.A. § 2404. A key component of this definition is that the custodian is “responsible [for the child] by authority of law.”
Brush v. Old Navy LLC (D. Vt. 2023). · cites it 2× “lawful authority[,]” 13 V.S.A. § 2404(3), and therefore did not falsely imprison Plaintiff.”
State v. O'DELL, 2007 VT 34 (Vt. 2007). “" 13 V.S.A. § 2404. A key component of this definition is that the custodian is "responsible [for the child] by authority of law.”
— Vt. Stat. Ann. tit. 13, § 2404(1) — 1 case
State v. Petruccelli, 743 A.2d 1062 (Vt. 1999). “If defendant is found to possess the same status as the father of a child born in wedlock, defendant argues he “necessarily qualifies” as a “lawful custodian” of the baby, pursuant to 13 V.S.A. § 2404(1) (lawful custodian is a “parent, guardian or other person responsible by…”
— Vt. Stat. Ann. tit. 13, § 2404(3) — 3 cases
State v. Washington, 691 A.2d 583 (Vt. 1997). “13 VS.A. § 2404(3) (“‘[r]estrain’ means to restrict substantially the movement of another person without the person’s consent or other lawful authority”).”
State v. Washington, 691 A.2d 583 (Vt. 1997). “Defendant asserts the evidence was insufficient to support the kidnapping charge because it failed to establish the element of restraint, which requires some substantial movement or confinement without the victim's consent.”
Brush v. Old Navy LLC (D. Vt. 2023). “lawful authority[,]” 13 V.S.A. § 2404(3), and therefore did not falsely imprison Plaintiff.”
— Vt. Stat. Ann. tit. 13, § 2404(3)(B) — 1 case
State v. Alexander, 795 A.2d 1248 (Vt. 2002). “Finally, defendant contends the evidence was insufficient to establish the element of restraint under the kidnapping statute because the victim was not confined for a "substantial" period nor moved a "substantial" distance.”
— Vt. Stat. Ann. tit. 13, § 2404(3)(C) — 6 cases
State v. Carrasquillo, 795 A.2d 1141 (Vt. 2002). “Defendant also argues on appeal that the evidence presented at trial was quantitatively insufficient, as a matter of law, to satisfy the “substantial period” element of Vermont’s kidnapping statute, 13 V.S.A. § 2404(3)(C). We affirm. Defendant Carrasquillo was an inmate at the…”
State v. Goodhue, 2003 VT 85 (Vt. 2003). “” The State relied on the definition of “restrain” found in 13 V.S.A. §2404(3)(C): “‘Restrain’ means to restrict substantially the movement of another person without the person’s consent or other lawful authority by confining the restrained person for a substantial period either…”
State v. Petruccelli, 743 A.2d 1062 (Vt. 1999). “If defendant is found to possess the same status as the father of a child born in wedlock, defendant argues he “necessarily qualifies” as a “lawful custodian” of the baby, pursuant to 13 V.S.A. § 2404(1) (lawful custodian is a “parent, guardian or other person responsible by…”
State v. Lang, 664 A.2d 267 (Vt. 1995). “The term “restrain” means “to restrict substantially the movement of another person without the person’s consent .”
State v. Jones, 2011 VT 90 (Vt. 2011). “In Lang , as in this case, the defendant argued that the victims were not confined for a “substantial period” as required by 13 V.S.A. § 2404(3)(C). The temporal duration of the restraint was relevant but not to the exclusion of other qualitative factors.”
— Vt. Stat. Ann. tit. 13, § 2404(4) — 2 cases
State v. Washington, 691 A.2d 583 (Vt. 1997). “13 VS.A. § 2404(3) (“‘[r]estrain’ means to restrict substantially the movement of another person without the person’s consent or other lawful authority”).”
State v. Washington, 691 A.2d 583 (Vt. 1997). “Defendant asserts the evidence was insufficient to support the kidnapping charge because it failed to establish the element of restraint, which requires some substantial movement or confinement without the victim's consent.”
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