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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 4820 (2026)

✓ current as of May 2026
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(Cite as: 13 V.S.A. § 4820)
Notes of Decisions
Cited in 26 cases (1 in the last 5 years), 1978–2024 · leading case: State v. Clarke, 496 A.2d 164 (Vt. 1985).
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State v. Clarke, 496 A.2d 164 (Vt. 1985). · cites it 5× “13 V.S.A. § 4820. Once a hospitalization hearing is triggered by one of those four events, the court must make a finding as to whether the defendant “is a person in need of treatment or a patient in need of further treatment” as defined in 18 V.”
Sharris v. Commonwealth, 106 N.E.3d 661 (Mass. 2018). “§ 77-15-6 ; Vt. Stat. Ann. tit. 13, §§ 4820 , 4822 ; Wyo.”
In re M.A., 2011 VT 9 (Vt. 2011). · cites it 3× “13 V.S.A. § 4820. ¶ 11. Defendant argues here, as below, that after the family court was founded in 1990, the Family Court Act requires all Act 248 hearings to be held only in the family court.”
In Re Ma, 2011 VT 9 (Vt. 2011). · cites it 3× “13 V.S.A. § 4820. ¶ 11. Defendant argues here, as below, that after the family court was founded in 1990, the Family Court Act requires all Act 248 hearings to be held only in the family court.”
State v. O'connell, 383 A.2d 624 (Vt. 1978). · cites it 2× “At a subsequent hospitalization hearing pursuant to 13 V.S.A. § 4820 on August 12, 1976, the district court issued an order resulting in respondent’s commitment to the Commissioner of Mental Health for an indefinite period, and on October 28, 1976, the criminal charges against…”
State v. J.S., 817 A.2d 53 (Vt. 2002). “13 V.S.A. § 4820; State v. O’Connell, 136 Vt.”
State v. Condrick, 477 A.2d 632 (Vt. 1984). “A hearing was held, pursuant to 13 V.S.A. § 4820, after which, the court found defendant to be incompetent.”
State v. Koch, 730 A.2d 577 (Vt. 1999). “See 13 V.S.A. § 4820(1). The court conducted the hospitalization hearing on April 22, 1997, pursuant to 13 V.”
State v. Curry, 2009 VT 89 (Vt. 2009). · cites it 2× “See 13 V.S.A. § 4820(2) (where a person is found to be incompetent “due to a mental disease or mental defect,” the court must hold a hearing to determine whether he or she should be committed); id.”
State v. Zorn, 2013 VT 65 (Vt. 2013). · cites it 2× “” 13 V.S.A. § 4820(1), (2). Both of these triggers were present here.”
State v. Williams, 467 A.2d 667 (Vt. 1983). “The formal hearing which the petitioners in Wisconsin sought parallels closely the hospitalization hearing which this defendant received by virtue of 13 V.S.A. § 4820, in that defendant had the same status and rights as a person subject to involuntary civil commitment.”
State v. Ladd, 433 A.2d 294 (Vt. 1981). “13 V.S.A. § 4820(1). The examining psychiatrist testified that the defendant was insane at the time of the offense.”
Show all 26 citing cases →
— Vt. Stat. Ann. tit. 13, § 4820(1) — 5 cases
State v. Clarke, 496 A.2d 164 (Vt. 1985). “13 V.S.A. § 4820. Once a hospitalization hearing is triggered by one of those four events, the court must make a finding as to whether the defendant “is a person in need of treatment or a patient in need of further treatment” as defined in 18 V.”
State v. Koch, 730 A.2d 577 (Vt. 1999). “See 13 V.S.A. § 4820(1). The court conducted the hospitalization hearing on April 22, 1997, pursuant to 13 V.”
State v. Ladd, 433 A.2d 294 (Vt. 1981). “13 V.S.A. § 4820(1). The examining psychiatrist testified that the defendant was insane at the time of the offense.”
State v. Zorn, 2013 VT 65 (Vt. 2013). “” 13 V.S.A. § 4820(1), (2). Both of these triggers were present here.”
State v. Zorn, 195 Vt. 381 (Vt. 2013).
— Vt. Stat. Ann. tit. 13, § 4820(2) — 4 cases
State v. Curry, 2009 VT 89 (Vt. 2009). “See 13 V.S.A. § 4820(2) (where a person is found to be incompetent “due to a mental disease or mental defect,” the court must hold a hearing to determine whether he or she should be committed); id.”
In re J.P. (Vt. 2015).
In re J.P. (Vt. 2015).
State v. Wright, 669 A.2d 553 (Vt. 1995).
— Vt. Stat. Ann. tit. 13, § 4820(3) — 2 cases
State v. Zorn, 2013 VT 65 (Vt. 2013). “” 13 V.S.A. § 4820(1), (2). Both of these triggers were present here.”
State v. Zorn, 195 Vt. 381 (Vt. 2013).
— Vt. Stat. Ann. tit. 13, § 4820(4) — 4 cases
In re M.A., 2011 VT 9 (Vt. 2011). “13 V.S.A. § 4820. ¶ 11. Defendant argues here, as below, that after the family court was founded in 1990, the Family Court Act requires all Act 248 hearings to be held only in the family court.”
In Re Ma, 2011 VT 9 (Vt. 2011). “13 V.S.A. § 4820. ¶ 11. Defendant argues here, as below, that after the family court was founded in 1990, the Family Court Act requires all Act 248 hearings to be held only in the family court.”
State v. Christopher A. Sharrow, 175 A.3d 504 (Vt. 2017).
State v. Curry, 2009 VT 89 (Vt. 2009). “See 13 V.S.A. § 4820(2) (where a person is found to be incompetent “due to a mental disease or mental defect,” the court must hold a hearing to determine whether he or she should be committed); id.”
— Vt. Stat. Ann. tit. 13, § 4820(a)(2) — 1 case
In re D.C. (Vt. 2015).
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