Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 3255 (2026)

✓ current as of May 2026
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Subchapter 001 : CRIMES; TRIAL

(Cite as: 13 V.S.A. § 3255)
Notes of Decisions
Cited in 35 cases (3 in the last 5 years), 1981–2025 · leading case: State v. Patnaude, 438 A.2d 402 (Vt. 1981).
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State v. Patnaude, 438 A.2d 402 (Vt. 1981). · cites it 16× “In fact, at the pretrial in camera hearing, held pursuant to 13 V.S.A. § 3255(b), to determine the admissibility of ten separate items of defense evidence, defense counsel specifically assured the trial judge that they were not seeking to have 13 V.”
State v. Memoli, 2011 VT 15 (Vt. 2011). · cites it 8× “The trial court cited two grounds for its decision to exclude evidence of complainant's prior and subsequent drug use: the rape shield statute and lack of relevancy to the issue of consent. Neither provides a legal basis for exclusion of defendant's proffered evidence.”
State v. Patten, 197 A.3d 873 (Vt. 2018). · cites it 7× “" 13 V.S.A. § 3255(a)(3) ; State v. Lavalette , 154 Vt.”
State v. Catsam, 534 A.2d 184 (Vt. 1987). · cites it 4× “The trial court barred this line of cross-examination on the basis of the Rape Shield Law, 13 V.S.A. § 3255. 3 Defendant maintains that the court’s application of the Rape Shield Law vi- *373 dated his right to be confronted with the witnesses against him, as guaranteed by the…”
State v. Ross, 568 A.2d 335 (Vt. 1989). · cites it 4× “The State moved in limine to exclude evidence of the victim's prior sexual conduct under the Rape Shield Law, 13 V.S.A. § 3255. During argument before jury selection, defense counsel indicated in somewhat vague terms that several named relatives and other unnamed people, in…”
State v. Goodnow, 649 A.2d 752 (Vt. 1994). · cites it 7× “13 V.S.A. § 3255(a)(3). The prohibition is based on a legislative determination that such evidence is worthless and legally irrelevant.”
State v. Gonyaw, 507 A.2d 944 (Vt. 1985). · cites it 6× “The State argues that decisions on the admissibility of evidence should be left to the discretion of the trial judge, and should not be overturned absent a showing of an abuse of discretion.”
State v. Bevins, 439 A.2d 271 (Vt. 1981). · cites it 5× “The defendant also claims that the trial court erred in excluding, under 13 V.S.A. § 3255 (a) (3), evidence of the sexual conduct between the complaining witness and a person other than the defendant on the night of the sexual assault.”
State v. Hammond, 2012 VT 48 (Vt. 2012). · cites it 3× “Defendant argues that: (1) he was entitled to a judgment of acquittal based on the complainant’s contradictory and otherwise *50 incredible testimony; (2) alternatively, he is entitled to a new trial for the same reasons; (3) the court’s jury instructions were erroneous; (4) the…”
People v. Fontana, 232 P.3d 1187 (Cal. 2010). “, rule 412(b)(1); Vt. Stat. Ann. tit. 13, § 3255 (a)(3)(B); Va.”
State v. Rehkop, 2006 VT 72 (Vt. 2006). “For example, in Roya , where the defendant challenged the constitutionality of a provision of our rape-shield statute, 13 V.S.A. § 3255(c), which prohibits a defendant from questioning a complaining witness during deposition about prior sexual conduct except in limited…”
State v. Burke, 2012 VT 50 (Vt. 2012). “13 V.S.A. § 3255(a)(3)(C). ¶20. Defendant contends that Judge Keller initially indicated that he would allow defendant to utilize the Rape Shield exception described above, but that Judge Katz refused to allow the evidence.”
Show all 35 citing cases →
— Vt. Stat. Ann. tit. 13, § 3255(a) — 5 cases
State v. Patnaude, 438 A.2d 402 (Vt. 1981). “In fact, at the pretrial in camera hearing, held pursuant to 13 V.S.A. § 3255(b), to determine the admissibility of ten separate items of defense evidence, defense counsel specifically assured the trial judge that they were not seeking to have 13 V.”
State v. Bevins, 439 A.2d 271 (Vt. 1981). “The defendant also claims that the trial court erred in excluding, under 13 V.S.A. § 3255 (a) (3), evidence of the sexual conduct between the complaining witness and a person other than the defendant on the night of the sexual assault.”
State v. Cate, 683 A.2d 1010 (Vt. 1996).
State v. Giroux, 561 A.2d 403 (Vt. 1989).
State v. Lavalette, 578 A.2d 108 (Vt. 1990).
— Vt. Stat. Ann. tit. 13, § 3255(a)(3) — 13 cases
State v. Patnaude, 438 A.2d 402 (Vt. 1981). “In fact, at the pretrial in camera hearing, held pursuant to 13 V.S.A. § 3255(b), to determine the admissibility of ten separate items of defense evidence, defense counsel specifically assured the trial judge that they were not seeking to have 13 V.”
State v. Memoli, 2011 VT 15 (Vt. 2011). “The trial court cited two grounds for its decision to exclude evidence of complainant's prior and subsequent drug use: the rape shield statute and lack of relevancy to the issue of consent. Neither provides a legal basis for exclusion of defendant's proffered evidence.”
State v. Catsam, 534 A.2d 184 (Vt. 1987). “The trial court barred this line of cross-examination on the basis of the Rape Shield Law, 13 V.S.A. § 3255. 3 Defendant maintains that the court’s application of the Rape Shield Law vi- *373 dated his right to be confronted with the witnesses against him, as guaranteed by the…”
State v. Patten, 197 A.3d 873 (Vt. 2018). “" 13 V.S.A. § 3255(a)(3) ; State v. Lavalette , 154 Vt.”
State v. Bevins, 439 A.2d 271 (Vt. 1981). “The defendant also claims that the trial court erred in excluding, under 13 V.S.A. § 3255 (a) (3), evidence of the sexual conduct between the complaining witness and a person other than the defendant on the night of the sexual assault.”
— Vt. Stat. Ann. tit. 13, § 3255(a)(3)(A) — 4 cases
State v. Patten, 197 A.3d 873 (Vt. 2018). “" 13 V.S.A. § 3255(a)(3) ; State v. Lavalette , 154 Vt.”
State v. Patnaude, 438 A.2d 402 (Vt. 1981). “In fact, at the pretrial in camera hearing, held pursuant to 13 V.S.A. § 3255(b), to determine the admissibility of ten separate items of defense evidence, defense counsel specifically assured the trial judge that they were not seeking to have 13 V.”
State v. Hammond, 2012 VT 48 (Vt. 2012). “Defendant argues that: (1) he was entitled to a judgment of acquittal based on the complainant’s contradictory and otherwise *50 incredible testimony; (2) alternatively, he is entitled to a new trial for the same reasons; (3) the court’s jury instructions were erroneous; (4) the…”
State v. Gonyaw, 507 A.2d 944 (Vt. 1985). “The State argues that decisions on the admissibility of evidence should be left to the discretion of the trial judge, and should not be overturned absent a showing of an abuse of discretion.”
— Vt. Stat. Ann. tit. 13, § 3255(a)(3)(B) — 3 cases
State v. Catsam, 534 A.2d 184 (Vt. 1987). “The trial court barred this line of cross-examination on the basis of the Rape Shield Law, 13 V.S.A. § 3255. 3 Defendant maintains that the court’s application of the Rape Shield Law vi- *373 dated his right to be confronted with the witnesses against him, as guaranteed by the…”
In Re Pannu, 2010 VT 58 (Vt. 2010).
State v. Hooper, 557 A.2d 880 (Vt. 1988).
— Vt. Stat. Ann. tit. 13, § 3255(a)(3)(C) — 5 cases
State v. Goodnow, 649 A.2d 752 (Vt. 1994). “13 V.S.A. § 3255(a)(3). The prohibition is based on a legislative determination that such evidence is worthless and legally irrelevant.”
State v. Burke, 2012 VT 50 (Vt. 2012). “13 V.S.A. § 3255(a)(3)(C). ¶20. Defendant contends that Judge Keller initially indicated that he would allow defendant to utilize the Rape Shield exception described above, but that Judge Katz refused to allow the evidence.”
State v. Leggett, 664 A.2d 271 (Vt. 1995).
State v. Andy LaGore, 2025 VT 41 (Vt. 2025).
In re: GH. (Haw. 2022).
— Vt. Stat. Ann. tit. 13, § 3255(b) — 4 cases
State v. Patten, 197 A.3d 873 (Vt. 2018). “" 13 V.S.A. § 3255(a)(3) ; State v. Lavalette , 154 Vt.”
State v. Gonyaw, 507 A.2d 944 (Vt. 1985). “The State argues that decisions on the admissibility of evidence should be left to the discretion of the trial judge, and should not be overturned absent a showing of an abuse of discretion.”
State v. Patnaude, 438 A.2d 402 (Vt. 1981). “In fact, at the pretrial in camera hearing, held pursuant to 13 V.S.A. § 3255(b), to determine the admissibility of ten separate items of defense evidence, defense counsel specifically assured the trial judge that they were not seeking to have 13 V.”
State v. Goodnow, 649 A.2d 752 (Vt. 1994). “13 V.S.A. § 3255(a)(3). The prohibition is based on a legislative determination that such evidence is worthless and legally irrelevant.”
— Vt. Stat. Ann. tit. 13, § 3255(c) — 2 cases
State v. Rehkop, 2006 VT 72 (Vt. 2006). “For example, in Roya , where the defendant challenged the constitutionality of a provision of our rape-shield statute, 13 V.S.A. § 3255(c), which prohibits a defendant from questioning a complaining witness during deposition about prior sexual conduct except in limited…”
State v. Roya, 708 A.2d 908 (Vt. 1998).
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