Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 4501 (2026)

✓ current as of May 2026
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(Cite as: 13 V.S.A. § 4501)
Notes of Decisions
Cited in 20 cases (2 in the last 5 years), 1981–2024 · leading case: State v. Delisle, 648 A.2d 632 (Vt. 1994).
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State v. Delisle, 648 A.2d 632 (Vt. 1994). · cites it 8× “See 13 V.S.A. § 4501. In the alternative, defendant requested that the court charge the jurors on the definition of manslaughter, and then instruct them to acquit if they found that he had committed that offense only.”
State v. Stewart, 438 A.2d 671 (Vt. 1981). · cites it 9× “The defendants’ ground for dismissal in all four cases is that the statute of limitations, 13 V.S.A. §§ 4501 and 4503, bars the actions.”
State v. Savva, 616 A.2d 774 (Vt. 1992). · cites it 2× “The State cannot now prosecute defendant for misdemeanor possession of marijuana, see 13 V.S.A. § 4501(d) (statute of limitations for misdemeanors is three years), so remanding this case to the trial court would serve no purpose.”
State v. Petrucelli, 592 A.2d 365 (Vt. 1991). · cites it 3× “In 1983, the statute of limitations for sexual assault, then found in 13 V.S.A. § 4501, was three years. In 1985, the statute of limitations was amended, extending the limitation period to six years.”
State of Vermont v. Christian J. Noll, 199 A.3d 1054 (Vt. 2018). “In addition, defendant contended that the State had failed to show conduct that met the statutory elements *1060 for stalking within the three-year statute of limitations, 13 V.S.A. § 4501, from when defendant was charged in June 2015.”
State v. Johnson, 612 A.2d 1114 (Vt. 1992). · cites it 2× “Until 1985, 13 V.S.A. § 4501 permitted prosecutions for unspecified crimes, including lewd or lascivious conduct with a *347 child, only within three years after the commission of the offense.”
In re D.K., Juv., 2012 VT 23 (Vt. 2012). · cites it 2× “Moreover, the State notes that prosecutions for sexual assault of child victims are permitted until “the earlier of the date the victim attains the age of 24 or 10 years from the date the offense is reported,” 13 V.S.A. § 4501(c), neither of which was reached in this case before…”
In Re Jones, 2009 VT 113 (Vt. 2009). “The superior court held that the criminal limitations period, set out in 13 V.S.A. §§ 4501 and 4503 1 , could not be waived.”
State v. Ashley Nutbrown-Covey, 169 A.3d 216 (Vt. 2017). “13 V.S.A. § 4501(e). Although the timeline goals for adjudicating the merits of a CHINS petition are not always met, the need to achieve permanency without undue delay for a child is paramount in our juvenile system.”
State v. Burns, 564 A.2d 593 (Vt. 1989). · cites it 2× “13 V.S.A. § 4501(d). 2 The charge had been brought against defendant more than three years after the date of the alleged offense.”
State v. Sauve, 666 A.2d 1164 (Vt. 1995). “Second, the age of the evidence at a second trial is a relatively insignificant factor when one considers that the statute of limitations for sexual offenses against children was recently extended to permit prosecution to be commenced within the earlier of the date the victim…”
State v. Larose, 479 A.2d 162 (Vt. 1984). · cites it 3× “a motion to *493 dismiss on the ground that the statute of limitations, 13 V.S.A. § 4501, barred his prosecution.”
Show all 20 citing cases →
— Vt. Stat. Ann. tit. 13, § 4501(a) — 4 cases
State v. Delisle, 648 A.2d 632 (Vt. 1994). “See 13 V.S.A. § 4501. In the alternative, defendant requested that the court charge the jurors on the definition of manslaughter, and then instruct them to acquit if they found that he had committed that offense only.”
State v. Michael W. Tobin, 199 A.3d 1069 (Vt. 2018).
State v. Jason Roberts, 2024 VT 32 (Vt. 2024).
State v. Jones, 2011 VT 90 (Vt. 2011).
— Vt. Stat. Ann. tit. 13, § 4501(b) — 1 case
In re Jones, 2009 VT 39 (Vt. 2009).
— Vt. Stat. Ann. tit. 13, § 4501(c) — 5 cases
In re D.K., Juv., 2012 VT 23 (Vt. 2012). “Moreover, the State notes that prosecutions for sexual assault of child victims are permitted until “the earlier of the date the victim attains the age of 24 or 10 years from the date the offense is reported,” 13 V.S.A. § 4501(c), neither of which was reached in this case before…”
State v. Petrucelli, 592 A.2d 365 (Vt. 1991). “In 1983, the statute of limitations for sexual assault, then found in 13 V.S.A. § 4501, was three years. In 1985, the statute of limitations was amended, extending the limitation period to six years.”
State v. Sauve, 666 A.2d 1164 (Vt. 1995). “Second, the age of the evidence at a second trial is a relatively insignificant factor when one considers that the statute of limitations for sexual offenses against children was recently extended to permit prosecution to be commenced within the earlier of the date the victim…”
State v. Johnson, 612 A.2d 1114 (Vt. 1992). “Until 1985, 13 V.S.A. § 4501 permitted prosecutions for unspecified crimes, including lewd or lascivious conduct with a *347 child, only within three years after the commission of the offense.”
State v. Robert E. Caron, Sr., 2020 VT 96 (Vt. 2020).
— Vt. Stat. Ann. tit. 13, § 4501(d) — 3 cases
State v. Delisle, 648 A.2d 632 (Vt. 1994). “See 13 V.S.A. § 4501. In the alternative, defendant requested that the court charge the jurors on the definition of manslaughter, and then instruct them to acquit if they found that he had committed that offense only.”
State v. Savva, 616 A.2d 774 (Vt. 1992). “The State cannot now prosecute defendant for misdemeanor possession of marijuana, see 13 V.S.A. § 4501(d) (statute of limitations for misdemeanors is three years), so remanding this case to the trial court would serve no purpose.”
State v. Burns, 564 A.2d 593 (Vt. 1989). “13 V.S.A. § 4501(d). 2 The charge had been brought against defendant more than three years after the date of the alleged offense.”
— Vt. Stat. Ann. tit. 13, § 4501(e) — 2 cases
State v. Ashley Nutbrown-Covey, 169 A.3d 216 (Vt. 2017). “13 V.S.A. § 4501(e). Although the timeline goals for adjudicating the merits of a CHINS petition are not always met, the need to achieve permanency without undue delay for a child is paramount in our juvenile system.”
In re Cherie Hyde, 2015 VT 106 (Vt. 2015).
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