Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 3 (2026)

✓ current as of May 2026
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(Cite as: 13 V.S.A. § 3)
Notes of Decisions
Cited in 28 cases, 1966–2015 · leading case: State v. Pitts, 800 A.2d 481 (Vt. 2002).
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State v. Pitts, 800 A.2d 481 (Vt. 2002). · cites it 4× “Defendant appeals a jury conviction in Chittenden District Court for accessory to aggravated assault in violation of 13 V.S.A. §§ 3 and 1024. Defendant argues that (1) the jury instructions on accomplice liability failed to require the jury to find that she shared in the…”
State v. Bacon, 658 A.2d 54 (Vt. 1995). · cites it 2× “We recognize that 13 V.S.A. § 3, which provides that "[a] person who aids in the commission of a felony shall be punished as a principal," does not include an intent element.”
State v. Davignon, 565 A.2d 1301 (Vt. 1989). · cites it 3× “*213 Defendant was charged with aiding in the commission of a felony by Larry Tabor in violation of 13 V.S.A. § 3 (one who aids in commission of a felony is punished as a principal).”
State v. Rebideau, 321 A.2d 58 (Vt. 1974). · cites it 5× “Defendant argues that the evidence, at best, was sufficient to convict him as an accessory aiding in the commission of a felony, pursuant to 13 V.S.A. § 3, and not as a principal committing murder in the first degree as was charged; further, that the two are separate and…”
State v. Miller, 502 A.2d 832 (Vt. 1985). · cites it 3× “In accordance with 13 V.S.A. § 3, the court instructed the jury that a finding of participation “in the execution of the unlawful design” would support conviction and that “[m]ere presence .”
State v. Neale, 491 A.2d 1025 (Vt. 1985). · cites it 2× “The trial judge in this case instructed the jury that it could find the defendant to be an accomplice to the felony of cultivating marijuana (and thus punishable as a principal) if it found that the defendant knowingly participated in a common plan or scheme to cultivate…”
State v. Stewart, 438 A.2d 671 (Vt. 1981). · cites it 3× “On the same day it also indicted Irene Stewart for aiding in the commission of the felony of embezzlement in violation of 13 V.S.A. §§ 3 and 2531. They pleaded not guilty and moved to dismiss the indictments.”
State v. Sowell, 728 A.2d 712 (Md. 1999). · cites it 2× “A Vermont statute similarly maintains the distinctions between principals and accessories, but provides that accessories may be punished as a principal, see VT. STAT. ANN. tit. 13, § 3 (1998), and need not be specifically charged.”
State v. Perez, 2006 VT 53 (Vt. 2006). · cites it 3× “Defendant Michael Perez appeals from his conviction, after a jury trial, of aiding in aggravated murder in violation of 13 V.S.A. §§ 3, 2301, 2311(a). He argues that: (1) the trial court erred in refusing to instruct the jury on a lesser-included offense of voluntary…”
State v. Wilder, 2010 VT 17 (Vt. 2010). · cites it 7× “See 13 V.S.A. § 3. However, the prosecution never charged defendants with aiding the other defendant’s commission of aggravated sexual assault.”
State v. Hamlin, 499 A.2d 45 (Vt. 1985). “During its case-in-chief, the State also developed a theory that the defendant was an “accomplice,” and could be held liable as a principal on that basis.”
State v. Jaramillo, 436 A.2d 757 (Vt. 1981). “The court instructed the jury that it could find the defendant guilty if he aided in the commission of the offense charged.”
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