Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 2451 (2026)

✓ current as of May 2026
Find cases: SyfertCases citing this section VT-LEGlegislature.vermont.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
(Cite as: 13 V.S.A. § 2451)
Notes of Decisions
Cited in 18 cases (3 in the last 5 years), 1996–2026 · leading case: State v. Austin, 685 A.2d 1076 (Vt. 1996).
Sort: Relevance Newest Treatment
State v. Austin, 685 A.2d 1076 (Vt. 1996). · cites it 2× “§ 3252(a)(1), and two counts of custodial interference, 13 V.S.A. § 2451. Defendant and the state's attorney signed a plea agreement in which defendant agreed to plead nolo contendere to the charge of sexual assault and the State agreed to dismiss the custodial interference…”
State v. Doyen, 676 A.2d 345 (Vt. 1996). · cites it 4× “In this case, we decide whether Vermont has jurisdiction to prosecute the offense of custodial interference, 13 V.S.A. § 2451, where the defendant commits no act within Vermont.”
State v. Patricia Kane, 169 A.3d 762 (Vt. 2017). “§ 2406(a)(3) and custodial interference pursuant to 13 V.S.A. § 2451. An information and accompanying affidavit were filed on January 28, 2014, the same day a warrant was issued for defendant's arrest.”
State v. Munoz, 2006 NMSC 5 (N.M. 2006). “26(2)(1) (2004) (requiring a reasonable belief); N.J. Stat Ann. § 2C:13-4(c)(l) (2005) (requiring a reasonable belief); Ohio Rev.”
Foster-Zahid v. Commonwealth, 477 S.E.2d 759 (Va. Ct. App. 1996). “” Vt. Stat. Ann. tit. 13, § 2451 (a) (1995) (emphasis added).”
State v. Petruccelli, 743 A.2d 1062 (Vt. 1999). “Custodial Interference The information with respect to the custodial interference charge alleged that “on the twenty-third day of October 1994, [the defendant] did knowingly and without legal right to do so, keep a child, to wit, Kristen Petruccelli, from her lawful custodian,…”
State v. Wootten, 756 A.2d 1222 (Vt. 2000). “” 13 V.S.A. § 2451(a). 4 It is undisputed that defendant is a relative of the boys and that they were less than eighteen years old when he removed them from Vermont.”
State v. O'Dell, 2007 VT 34 (Vt. 2007). · cites it 4× “§ 3001, and custodial interference under 13 V.S.A. § 2451(a). At trial, defendant moved for acquittal pursuant to Vermont Rule of Criminal Procedure 29(a), arguing that there was insufficient evidence to demonstrate that she impeded the officer and that she did not receive…”
State v. Liana M. Roy, 203 A.3d 1177 (Vt. 2018). “29, arguing that the evidence failed to demonstrate that she interfered with DCF's custody to the degree necessary for 13 V.S.A. § 2451 to apply. At most, defendant argued, this was just "a visit gone bad.”
State v. O'DELL, 2007 VT 34 (Vt. 2007). · cites it 4× “§ 3001, and custodial interference under 13 V.S.A. § 2451(a). At trial, defendant moved for acquittal pursuant to Vermont Rule of Criminal Procedure 29(a), arguing that there was insufficient evidence to demonstrate that she impeded the officer and that she did not receive…”
State v. Liana M. Roy, 2018 VT 67 (Vt. 2018). · cites it 2× “Defendant Liana Roy was convicted of custodial interference for taking her four-year-old daughter, who was then in DCF custody, on a two-day trip out of the state without DCF’s permission.”
State v. Patricia Kane, 2016 VT 121 (Vt. 2016). “Defendant pleaded guilty to custodial interference in violation of 13 V.S.A. § 2451. In October 2014, she was sentenced to two-to-five years, all suspended except one year.”
Show all 18 citing cases →
— Vt. Stat. Ann. tit. 13, § 2451(a) — 6 cases
State v. Doyen, 676 A.2d 345 (Vt. 1996). “In this case, we decide whether Vermont has jurisdiction to prosecute the offense of custodial interference, 13 V.S.A. § 2451, where the defendant commits no act within Vermont.”
State v. Wootten, 756 A.2d 1222 (Vt. 2000). “” 13 V.S.A. § 2451(a). 4 It is undisputed that defendant is a relative of the boys and that they were less than eighteen years old when he removed them from Vermont.”
State v. O'Dell, 2007 VT 34 (Vt. 2007). “§ 3001, and custodial interference under 13 V.S.A. § 2451(a). At trial, defendant moved for acquittal pursuant to Vermont Rule of Criminal Procedure 29(a), arguing that there was insufficient evidence to demonstrate that she impeded the officer and that she did not receive…”
State v. O'DELL, 2007 VT 34 (Vt. 2007). “§ 3001, and custodial interference under 13 V.S.A. § 2451(a). At trial, defendant moved for acquittal pursuant to Vermont Rule of Criminal Procedure 29(a), arguing that there was insufficient evidence to demonstrate that she impeded the officer and that she did not receive…”
Dudley v. Burlington (Vt. Super. Ct. 2026).
— Vt. Stat. Ann. tit. 13, § 2451(c) — 1 case
Jenkins v. Miller (D. Vt. 2025).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.