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Vt. Stat. Ann. tit. 13, § 4822 (2026)

Findings and order; persons with a mental illness

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(Cite as: 13 V.S.A. § 4822)
Notes of Decisions
Cited in 21 cases (1 in the last 5 years), 1977–2024 · leading case: State v. J.S., 817 A.2d 53 (Vt. 2002).
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State v. J.S., 817 A.2d 53 (Vt. 2002). · cites it 5× “Appellant appeals from an order of the district court involuntarily hospitalizing him for ninety days pursuant to 13 V.S.A. § 4822 after appellant was found not competent to stand trial.”
State v. Clarke, 496 A.2d 164 (Vt. 1985). · cites it 7× “§ 4814, and ordered hospitalized pursuant to 13 V.S.A. § 4822, may subsequently be tried for the charged offense.”
State v. O'connell, 383 A.2d 624 (Vt. 1978). · cites it 3× “The respondent was involuntarily committed pursuant to 13 V.S.A. § 4822 by the District Court of Vermont, Unit No.”
State v. B.C., 2016 VT 66, 149 A.3d 143. · cites it 20× “An order issued under 13 V.S.A. § 4822 has the same force and effect as an order issued under 18 V.”
State v. Mayer, 423 A.2d 492 (Vt. 1980). · cites it 6× “The “indeterminate” hospitalization order permitted under subsection (a) of 13 V.S.A. § 4822 appears to be inconsistent with the “force and effect” of the initial 90-day hospitalization limitation under 18 V.”
State v. Williams, 467 A.2d 667 (Vt. 1983). · cites it 3× “Defendant pled not guilty by reason of insanity, and a psychiatric examination was ordered.”
State v. Zorn, 2013 VT 65, 88 A.3d 1164. · cites it 4× “Zorn appeals the superior court’s order involuntarily hospitalizing him for a period of ninety days pursuant to 13 V.S.A. § 4822. 1 Defendant first contends that the hospitalization order was improper because there was insufficient evidence to establish that he was a person in…”
State v. O'connell, 375 A.2d 982 (Vt. 1977). · cites it 2× “5, Washington Circuit, issued in accordance with 13 V.S.A. § 4822. Three weeks after this order, he petitioned the Washington Superior Court for review.”
State v. Condrick, 477 A.2d 632 (Vt. 1984). “The findings here do not satisfy the requirements of 13 V.S.A. § 4822. Section 7101(17) requires a finding that defendant is “suffering from mental illness and .”
State v. Koch, 730 A.2d 577 (Vt. 1999). “See 13 V.S.A. § 4822. 4 The mere adoption of the civil commitment *116 “procedures” for the conduct of hearings pursuant to Title 13 is not sufficient to deduce, as defendant suggests, that the Legislature intended to distance hospitalization hearings from the criminal context…”
State v. Curry, 2009 VT 89, 987 A.2d 265. · cites it 2× “§§ 7101(17), 7611; 13 V.S.A. § 4822. As indicated above, for someone to be a “person in need of treatment,” a court must find that the person “is suffering from mental illness and, as a result of that mental illness, his or her capacity to exercise self-control, judgment or…”
State v. Ladd, 433 A.2d 294 (Vt. 1981). “The court later that same day issued findings, which in substance merely recited the diagnostic label used by the psychiatrist, combined with statutory language from 18 V.”
Show all 21 citing cases →
Vt. Stat. Ann. tit. 13, § 4822(a): 10 cases
State v. B.C., 2016 VT 66, 149 A.3d 143. “An order issued under 13 V.S.A. § 4822 has the same force and effect as an order issued under 18 V.”
State v. Zorn, 2013 VT 65, 88 A.3d 1164. “Zorn appeals the superior court’s order involuntarily hospitalizing him for a period of ninety days pursuant to 13 V.S.A. § 4822. 1 Defendant first contends that the hospitalization order was improper because there was insufficient evidence to establish that he was a person in…”
State v. Ladd, 433 A.2d 294 (Vt. 1981). “The court later that same day issued findings, which in substance merely recited the diagnostic label used by the psychiatrist, combined with statutory language from 18 V.”
State v. Curry, 2009 VT 89, 987 A.2d 265. “§§ 7101(17), 7611; 13 V.S.A. § 4822. As indicated above, for someone to be a “person in need of treatment,” a court must find that the person “is suffering from mental illness and, as a result of that mental illness, his or her capacity to exercise self-control, judgment or…”
State v. Mayer, 423 A.2d 492 (Vt. 1980). “The “indeterminate” hospitalization order permitted under subsection (a) of 13 V.S.A. § 4822 appears to be inconsistent with the “force and effect” of the initial 90-day hospitalization limitation under 18 V.”
Vt. Stat. Ann. tit. 13, § 4822(b): 4 cases
State v. Mayer, 423 A.2d 492 (Vt. 1980). “The “indeterminate” hospitalization order permitted under subsection (a) of 13 V.S.A. § 4822 appears to be inconsistent with the “force and effect” of the initial 90-day hospitalization limitation under 18 V.”
State v. O'connell, 375 A.2d 982 (Vt. 1977). “5, Washington Circuit, issued in accordance with 13 V.S.A. § 4822. Three weeks after this order, he petitioned the Washington Superior Court for review.”
State v. B.C., 2016 VT 66, 149 A.3d 143. “An order issued under 13 V.S.A. § 4822 has the same force and effect as an order issued under 18 V.”
State v. B.C. / State v. D.H., 2016 VT 66.
Vt. Stat. Ann. tit. 13, § 4822(c): 3 cases
State v. B.C., 2016 VT 66, 149 A.3d 143. “An order issued under 13 V.S.A. § 4822 has the same force and effect as an order issued under 18 V.”
State v. B.C. / State v. D.H., 2016 VT 66.
State v. Michael A. Armstrong, 2024 VT 5, 312 A.3d 545.
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