Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 4801 (2026)

✓ current as of May 2026
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(Cite as: 13 V.S.A. § 4801)
Notes of Decisions
Cited in 33 cases (3 in the last 5 years), 1969–2025 · leading case: State v. Sexton, 2006 VT 55 (Vt. 2006).
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State v. Sexton, 2006 VT 55 (Vt. 2006). · cites it 26× “and the effects of voluntary consumption of illegal drugs apply to a charge of second degree murder based upon wanton disregard of the likelihood that one's conduct would naturally cause death or great bodily harm, so as to reduce the offense to voluntary manslaughter? *1097 (3)…”
State v. Messier, 497 A.2d 740 (Vt. 1985). · cites it 3× “This is an interlocutory appeal from a decision of the Orleans District Court, holding Vermont’s insanity defense statute, 13 V.S.A. § 4801 (b), unconstitutional. Clifford Messier, the defendant, stands charged with murder in the first degree.”
State v. Smith, 396 A.2d 126 (Vt. 1978). · cites it 3× “The test of responsibility for criminal conduct is set out in 13 V.S.A. § 4801: The test when used as a defense in criminal cases shall be as follows: (1) A person is not responsible for criminal conduct if at the time of such conduct as a result of mental disease or defect he…”
State v. Willis, 494 A.2d 108 (Vt. 1985). · cites it 2× “Thus, defendant advanced an insanity defense under the former 13 V.S.A. § 4801, now 13 V.S.A. § 4801(a).”
State v. Howe, 386 A.2d 1125 (Vt. 1978). · cites it 2× “" 13 V.S.A. § 4801. Taking the evidence in the light most favorable to the State, State v.”
State v. Bishop, 260 A.2d 393 (Vt. 1969). · cites it 4× “The test of insanity as a defense in criminal cases in this State appears in 13 V.S.A. § 4801 and is as follows: (1) A person is not responsible for criminal conduct if at the time of such conduct as a result of mental disease or defect he lacks adequate capacity either to…”
State v. Smith, 437 A.2d 1093 (Vt. 1981). · cites it 4× “§ 4801: (1) A person is not responsible for criminal conduct if at the time of such conduct as a result of mental disease or defect he lacks adequate capacity either to appreciate the criminality of his conduct or to conform his conduct to the requirements of law.”
State v. Percy, 548 A.2d 408 (Vt. 1988). · cites it 2× “See 13 V.S.A. § 4801(a)(1). In reaching a conclusion on this question, our law requires the fact-finder to exclude “abnormality manifested only by repeated criminal or otherwise anti-social conduct.”
State v. Bean, 762 A.2d 1259 (Vt. 2000). · cites it 2× “13 V.S.A. § 4801(b). A defendant raising an insanity defense must give notice thereof on the date of the status conference, or ten days prior to trial, whichever is sooner.”
State v. Valley, 571 A.2d 579 (Vt. 1989). · cites it 2× “" See 13 V.S.A. § 4801(a)(2). There is an additional concern about the evidence here, not present in Catsam and cases similar to it: whether the statistical evidence can be perceived as expert testimony about the probability that the defendant was guilty, or in this case not…”
State v. Matthew Webster, 179 A.3d 149 (Vt. 2017). “13 V.S.A. § 4801(b). When the Legislature shifted the burden to the defendant to establish insanity, it evidenced an intent that sanity not be an essential element of the crime.”
State v. Davignon, 565 A.2d 1301 (Vt. 1989). · cites it 2× “In that case we upheld the validity of 13 V.S.A. § 4801(b) which, by a 1983 amendment, shifted the burden of proof on insanity to the defendant, to be established by a preponderance of the evidence.”
Show all 33 citing cases →
— Vt. Stat. Ann. tit. 13, § 4801(a) — 5 cases
State v. Willis, 494 A.2d 108 (Vt. 1985). “Thus, defendant advanced an insanity defense under the former 13 V.S.A. § 4801, now 13 V.S.A. § 4801(a).”
State v. Messier, 497 A.2d 740 (Vt. 1985). “This is an interlocutory appeal from a decision of the Orleans District Court, holding Vermont’s insanity defense statute, 13 V.S.A. § 4801 (b), unconstitutional. Clifford Messier, the defendant, stands charged with murder in the first degree.”
State v. Clarke, 496 A.2d 164 (Vt. 1985).
State v. Steven D. Bourgoin, 2021 VT 15 (Vt. 2021).
State v. Steven D. Bourgoin, 2021 VT 15 (Vt. 2021).
— Vt. Stat. Ann. tit. 13, § 4801(a)(1) — 5 cases
State v. Sexton, 2006 VT 55 (Vt. 2006). “and the effects of voluntary consumption of illegal drugs apply to a charge of second degree murder based upon wanton disregard of the likelihood that one's conduct would naturally cause death or great bodily harm, so as to reduce the offense to voluntary manslaughter? *1097 (3)…”
State v. Cong., 2014 VT 129 (Vt. 2014).
State v. Percy, 548 A.2d 408 (Vt. 1988). “See 13 V.S.A. § 4801(a)(1). In reaching a conclusion on this question, our law requires the fact-finder to exclude “abnormality manifested only by repeated criminal or otherwise anti-social conduct.”
Coop. Fire Ins. Ass'n v. Combs, 648 A.2d 857 (Vt. 1994).
Prop. & Cas. Ins. v. Davenport, 907 F. Supp. 2d 561 (D. Vt. 2012).
— Vt. Stat. Ann. tit. 13, § 4801(a)(2) — 4 cases
State v. Sexton, 2006 VT 55 (Vt. 2006). “and the effects of voluntary consumption of illegal drugs apply to a charge of second degree murder based upon wanton disregard of the likelihood that one's conduct would naturally cause death or great bodily harm, so as to reduce the offense to voluntary manslaughter? *1097 (3)…”
State v. Valley, 571 A.2d 579 (Vt. 1989). “" See 13 V.S.A. § 4801(a)(2). There is an additional concern about the evidence here, not present in Catsam and cases similar to it: whether the statistical evidence can be perceived as expert testimony about the probability that the defendant was guilty, or in this case not…”
State v. Percy, 612 A.2d 1119 (Vt. 1992).
State v. Percy, 548 A.2d 408 (Vt. 1988). “See 13 V.S.A. § 4801(a)(1). In reaching a conclusion on this question, our law requires the fact-finder to exclude “abnormality manifested only by repeated criminal or otherwise anti-social conduct.”
— Vt. Stat. Ann. tit. 13, § 4801(b) — 8 cases
State v. Sexton, 2006 VT 55 (Vt. 2006). “and the effects of voluntary consumption of illegal drugs apply to a charge of second degree murder based upon wanton disregard of the likelihood that one's conduct would naturally cause death or great bodily harm, so as to reduce the offense to voluntary manslaughter? *1097 (3)…”
State v. Bean, 762 A.2d 1259 (Vt. 2000). “13 V.S.A. § 4801(b). A defendant raising an insanity defense must give notice thereof on the date of the status conference, or ten days prior to trial, whichever is sooner.”
State v. Matthew Webster, 179 A.3d 149 (Vt. 2017). “13 V.S.A. § 4801(b). When the Legislature shifted the burden to the defendant to establish insanity, it evidenced an intent that sanity not be an essential element of the crime.”
State v. Davignon, 565 A.2d 1301 (Vt. 1989). “In that case we upheld the validity of 13 V.S.A. § 4801(b) which, by a 1983 amendment, shifted the burden of proof on insanity to the defendant, to be established by a preponderance of the evidence.”
State v. Messier, 497 A.2d 740 (Vt. 1985). “This is an interlocutory appeal from a decision of the Orleans District Court, holding Vermont’s insanity defense statute, 13 V.S.A. § 4801 (b), unconstitutional. Clifford Messier, the defendant, stands charged with murder in the first degree.”
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