Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 354 (2026)

✓ current as of May 2026 Cite as: Vt. Stat. Ann. tit. 13, § 354 (2026)
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Subchapter 001 : CRUELTY TO ANIMALS

(Cite as: 13 V.S.A. § 354)
Notes of Decisions
Cited in 14 cases (4 in the last 5 years), 1999–2026 · leading case: State v. Allan Washburn
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State v. Allan Washburn (2024) vt · cites it 9× “On appeal, defendant argues that the criminal division lacked jurisdiction over the forfeiture proceeding because Chad was not seized under 13 V.S.A. § 354, that the State failed to prove animal cruelty by clear and convincing evidence under 13 V.”
Hegarty v. Addison County Humane Society (2004) vt · cites it 4× “We agree with the Hegartys that humane officers should, whenever possible, obtain a warrant prior to seizing an animal, but, when the circumstances demand it and the statutory procedures are followed, humane officers have the authority to seize animals without a warrant.”
State v. Eldredge (2006) vt · cites it 2× “Until the court ordered forfeiture, the animals had been boarded at WCHS and fed, exercised, and given necessary veterinary treatment and care pursuant to 13 V.S.A. § 354(c). One dog was destroyed, but the others recovered from their maladies and, upon forfeiture, were put up…”
State v. Stevens (2004) vt · cites it 3× “Defendant Peggy Stevens appeals an order from the Windsor District Court denying her motion to suppress evidence of the condition of animals seized pursuant to 13 V.S.A. § 354(b)(3). The court found that defendant consented to the search of the animals and, in any event, the…”
State v. Randall J. Sheperd (2017) vt · cites it 10× “" *620 The warrant was issued pursuant to 13 V.S.A. § 354(b)(2), which allows a humane officer to apply for a search warrant upon probable cause that an animal is being subjected to cruelty.”
State v. Thomas Ferguson and Katherine A. Ferguson (2020) vt · cites it 9× “The trial court held a forfeiture hearing pursuant to 13 V.S.A. § 354. In the forfeiture hearing, the State presented testimony from an employee at the Humane Society, various photographs of defendants’ home and the animals, the testimony of Trooper June, and the affidavit of…”
State v. Kornell (1999) vt “In July 1993, pursuant to a search warrant, a humane officer accompanied by several police officers seized eighteen dogs, twelve rabbits, and four sheep from defendant’s home pursuant to 13 VS.A § 354(b)(2) (humane officer having probable cause to believe that animal is being…”
State v. Johnathan Ruiz (2025) vt · cites it 6× “In connection with these charges, the State moved for an animal-forfeiture order under 13 V.S.A. § 354, which the court granted.”
State v. Emily K. St. Peter (2018) vt · cites it 4× “A humane officer having probable cause to believe an animal is being subjected to cruel treatment in violation of this subchapter may apply for a search warrant pursuant to the Vermont Rules of Criminal Procedure to authorize the officer to enter the premises where the animal is…”
State v. Raymond Regimbald (2022) vt “See 13 V.S.A. § 354(f)(2). We explained that the statute “create[d] a limited exception to the hearsay rule” for sworn statements from law-enforcement officers but did not create “a blanket exception” for other hearsay statements contained within the affidavit, such as…”
State v. Bruce Bona (2015) vt · cites it 2× “At the outset of the first day of the hearing, the court denied defendant’s motion to continue, noting the statutory requirement that a hearing be held within twenty-one days of a seizure.”
State . Russell Goodell (2016) vt “Under 13 V.S.A. § 354(g)(1), a defendant convicted of animal cruelty “shall be required to repay all reasonable costs incurred by the custodial caregiver for caring for the animal, including veterinary expenses.”
Show all 14 citing cases →
— Vt. Stat. Ann. tit. 13, § 354(a) — 1 case
State v. Bruce Bona (2015) vt
— Vt. Stat. Ann. tit. 13, § 354(b) — 1 case
State v. Emily K. St. Peter (2018) vt “A humane officer having probable cause to believe an animal is being subjected to cruel treatment in violation of this subchapter may apply for a search warrant pursuant to the Vermont Rules of Criminal Procedure to authorize the officer to enter the premises where the animal is…”
— Vt. Stat. Ann. tit. 13, § 354(b)(1) — 1 case
State v. Emily K. St. Peter (2018) vt “A humane officer having probable cause to believe an animal is being subjected to cruel treatment in violation of this subchapter may apply for a search warrant pursuant to the Vermont Rules of Criminal Procedure to authorize the officer to enter the premises where the animal is…”
— Vt. Stat. Ann. tit. 13, § 354(b)(2) — 3 cases
State v. Randall J. Sheperd (2017) vt “" *620 The warrant was issued pursuant to 13 V.S.A. § 354(b)(2), which allows a humane officer to apply for a search warrant upon probable cause that an animal is being subjected to cruelty.”
State v. Kornell (1999) vt “In July 1993, pursuant to a search warrant, a humane officer accompanied by several police officers seized eighteen dogs, twelve rabbits, and four sheep from defendant’s home pursuant to 13 VS.A § 354(b)(2) (humane officer having probable cause to believe that animal is being…”
State v. Emily K. St. Peter (2018) vt “A humane officer having probable cause to believe an animal is being subjected to cruel treatment in violation of this subchapter may apply for a search warrant pursuant to the Vermont Rules of Criminal Procedure to authorize the officer to enter the premises where the animal is…”
— Vt. Stat. Ann. tit. 13, § 354(b)(3) — 3 cases
Hegarty v. Addison County Humane Society (2004) vt “We agree with the Hegartys that humane officers should, whenever possible, obtain a warrant prior to seizing an animal, but, when the circumstances demand it and the statutory procedures are followed, humane officers have the authority to seize animals without a warrant.”
State v. Stevens (2004) vt “Defendant Peggy Stevens appeals an order from the Windsor District Court denying her motion to suppress evidence of the condition of animals seized pursuant to 13 V.S.A. § 354(b)(3). The court found that defendant consented to the search of the animals and, in any event, the…”
State v. Randall J. Sheperd (2017) vt “" *620 The warrant was issued pursuant to 13 V.S.A. § 354(b)(2), which allows a humane officer to apply for a search warrant upon probable cause that an animal is being subjected to cruelty.”
— Vt. Stat. Ann. tit. 13, § 354(c) — 1 case
State v. Eldredge (2006) vt “Until the court ordered forfeiture, the animals had been boarded at WCHS and fed, exercised, and given necessary veterinary treatment and care pursuant to 13 V.S.A. § 354(c). One dog was destroyed, but the others recovered from their maladies and, upon forfeiture, were put up…”
— Vt. Stat. Ann. tit. 13, § 354(d) — 4 cases
State v. Allan Washburn (2024) vt “On appeal, defendant argues that the criminal division lacked jurisdiction over the forfeiture proceeding because Chad was not seized under 13 V.S.A. § 354, that the State failed to prove animal cruelty by clear and convincing evidence under 13 V.”
State v. Thomas Ferguson and Katherine A. Ferguson (2020) vt “The trial court held a forfeiture hearing pursuant to 13 V.S.A. § 354. In the forfeiture hearing, the State presented testimony from an employee at the Humane Society, various photographs of defendants’ home and the animals, the testimony of Trooper June, and the affidavit of…”
State v. Johnathan Ruiz (2025) vt “In connection with these charges, the State moved for an animal-forfeiture order under 13 V.S.A. § 354, which the court granted.”
State v. Bruce Bona (2015) vt “At the outset of the first day of the hearing, the court denied defendant’s motion to continue, noting the statutory requirement that a hearing be held within twenty-one days of a seizure.”
— Vt. Stat. Ann. tit. 13, § 354(f) — 2 cases
State v. Stevens (2004) vt “Defendant Peggy Stevens appeals an order from the Windsor District Court denying her motion to suppress evidence of the condition of animals seized pursuant to 13 V.S.A. § 354(b)(3). The court found that defendant consented to the search of the animals and, in any event, the…”
State v. Bruce Bona (2015) vt “At the outset of the first day of the hearing, the court denied defendant’s motion to continue, noting the statutory requirement that a hearing be held within twenty-one days of a seizure.”
— Vt. Stat. Ann. tit. 13, § 354(f)(1) — 5 cases
State v. Allan Washburn (2024) vt “On appeal, defendant argues that the criminal division lacked jurisdiction over the forfeiture proceeding because Chad was not seized under 13 V.S.A. § 354, that the State failed to prove animal cruelty by clear and convincing evidence under 13 V.”
State v. Thomas Ferguson and Katherine A. Ferguson (2020) vt “The trial court held a forfeiture hearing pursuant to 13 V.S.A. § 354. In the forfeiture hearing, the State presented testimony from an employee at the Humane Society, various photographs of defendants’ home and the animals, the testimony of Trooper June, and the affidavit of…”
State v. Randall J. Sheperd (2017) vt “" *620 The warrant was issued pursuant to 13 V.S.A. § 354(b)(2), which allows a humane officer to apply for a search warrant upon probable cause that an animal is being subjected to cruelty.”
State v. Johnathan Ruiz (2025) vt “In connection with these charges, the State moved for an animal-forfeiture order under 13 V.S.A. § 354, which the court granted.”
State of Vermont v. Sabrina Duvernay (2026) vt
— Vt. Stat. Ann. tit. 13, § 354(f)(2) — 2 cases
State v. Thomas Ferguson and Katherine A. Ferguson (2020) vt “The trial court held a forfeiture hearing pursuant to 13 V.S.A. § 354. In the forfeiture hearing, the State presented testimony from an employee at the Humane Society, various photographs of defendants’ home and the animals, the testimony of Trooper June, and the affidavit of…”
State v. Raymond Regimbald (2022) vt “See 13 V.S.A. § 354(f)(2). We explained that the statute “create[d] a limited exception to the hearsay rule” for sworn statements from law-enforcement officers but did not create “a blanket exception” for other hearsay statements contained within the affidavit, such as…”
— Vt. Stat. Ann. tit. 13, § 354(g)(1) — 4 cases
State v. Eldredge (2006) vt “Until the court ordered forfeiture, the animals had been boarded at WCHS and fed, exercised, and given necessary veterinary treatment and care pursuant to 13 V.S.A. § 354(c). One dog was destroyed, but the others recovered from their maladies and, upon forfeiture, were put up…”
State v. Randall J. Sheperd (2017) vt “" *620 The warrant was issued pursuant to 13 V.S.A. § 354(b)(2), which allows a humane officer to apply for a search warrant upon probable cause that an animal is being subjected to cruelty.”
State . Russell Goodell (2016) vt “Under 13 V.S.A. § 354(g)(1), a defendant convicted of animal cruelty “shall be required to repay all reasonable costs incurred by the custodial caregiver for caring for the animal, including veterinary expenses.”
State v. Johnathan Ruiz (2025) vt “In connection with these charges, the State moved for an animal-forfeiture order under 13 V.S.A. § 354, which the court granted.”
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