Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 5232 (2026)

✓ current as of May 2026
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Subchapter 002 : NOTICE AND NATURE OF RIGHTS

(Cite as: 13 V.S.A. § 5232)
Notes of Decisions
Cited in 16 cases (1 in the last 5 years), 1976–2021 · leading case: In re R.W. & N.W., 2011 VT 124 (Vt. 2011).
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In re R.W. & N.W., 2011 VT 124 (Vt. 2011). · cites it 2× “” 13 V.S.A. § 5232(3); see Lassiter v. Dep’t of Social Servs.”
Mullin v. Phelps, 647 A.2d 714 (Vt. 1994). · cites it 2× “See 13 V.S.A. § 5232(3) (court shall assign counsel to needy persons, including parents, in juvenile proceedings when interest of justice requires it).”
In re G.F., 923 A.2d 578 (Vt. 2007). “” 13 V.S.A. § 5232(3). There was no way on this record that the family court could make an informed decision that the interests of justice required counsel.”
In re C.B., Juv., 2020 VT 80 (Vt. 2020). “Father also contends that he was improperly denied standing at the merits stage of the CHINS proceeding and was erroneously not granted counsel until after the initial disposition order issued. There is no merit to father’s argument that the court failed to properly assign him…”
In re L.H., L.H. & L.H., Juveniles, 182 A.3d 612 (Vt. 2018). “§ 5112(a) ("The Court shall appoint an attorney for a child who is a party to a proceeding brought under the juvenile judicial proceedings chapters.”
Conway v. Cumming, 636 A.2d 735 (Vt. 1993). “Moreover, in Fletcher , the inmate was involved in a habeas proceeding for which counsel is expressly provided in 13 V.S.A. § 5232(2). No equivalent statutory right exists for representation in disciplinary proceedings.”
In re S.C., 88 A.3d 1220 (Vt. 2014). “” 13 V.S.A. § 5232(3). By administrative order, this Court has also ensured continued representation of *419 aggrieved parents on appeal, by providing that an appeal from a termination judgment is “not considered a separate proceeding and thus does not require a separate…”
In Re Morse, 415 A.2d 232 (Vt. 1980). “” 13 V.S.A. §§ 5232(2), 5233(a) (3). The defendant claims that he is a needy person confined in a penal institute, and that he considers this post-conviction proceeding appropriate.”
In Re Chapman, 581 A.2d 1041 (Vt. 1990). “See 13 V.S.A. § 5232(2). In Finley , the Supreme Court considered whether appointed counsel in a post-conviction review proceeding was constitutionally required to go through the procedure set forth in Anders v.”
In re M.T., G.T., B.T. & N.T., Juveniles, 179 A.3d 754 (Vt. 2017). · cites it 2× “" 13 V.S.A. § 5232(3). "Although in theory the appointment of counsel under § 5232(3) thus remains discretionary, in practice counsel are uniformly appointed to represent needy parents in termination proceedings from trial through appeal.”
Fletcher v. Gorczyk, 624 A.2d 1132 (Vt. 1992). “” 13 V.S.A. § 5232(2). If a person under conviction of a serious crime does not have an attorney and does not waive the right to have an attorney, the court must notify the appropriate public defender “upon commencement of any later judicial proceeding relating to the same…”
In re A. C., 357 A.2d 536 (Vt. 1976). “Under 13 V.S.A. § 5232, the right to assigned counsel is extended, along with criminal respondents, to needy persons in juvenile court proceedings.”
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— Vt. Stat. Ann. tit. 13, § 5232(2) — 4 cases
Conway v. Cumming, 636 A.2d 735 (Vt. 1993). “Moreover, in Fletcher , the inmate was involved in a habeas proceeding for which counsel is expressly provided in 13 V.S.A. § 5232(2). No equivalent statutory right exists for representation in disciplinary proceedings.”
In Re Morse, 415 A.2d 232 (Vt. 1980). “” 13 V.S.A. §§ 5232(2), 5233(a) (3). The defendant claims that he is a needy person confined in a penal institute, and that he considers this post-conviction proceeding appropriate.”
In Re Chapman, 581 A.2d 1041 (Vt. 1990). “See 13 V.S.A. § 5232(2). In Finley , the Supreme Court considered whether appointed counsel in a post-conviction review proceeding was constitutionally required to go through the procedure set forth in Anders v.”
Fletcher v. Gorczyk, 624 A.2d 1132 (Vt. 1992). “” 13 V.S.A. § 5232(2). If a person under conviction of a serious crime does not have an attorney and does not waive the right to have an attorney, the court must notify the appropriate public defender “upon commencement of any later judicial proceeding relating to the same…”
— Vt. Stat. Ann. tit. 13, § 5232(3) — 9 cases
In re R.W. & N.W., 2011 VT 124 (Vt. 2011). “” 13 V.S.A. § 5232(3); see Lassiter v. Dep’t of Social Servs.”
Mullin v. Phelps, 647 A.2d 714 (Vt. 1994). “See 13 V.S.A. § 5232(3) (court shall assign counsel to needy persons, including parents, in juvenile proceedings when interest of justice requires it).”
In re G.F., 923 A.2d 578 (Vt. 2007). “” 13 V.S.A. § 5232(3). There was no way on this record that the family court could make an informed decision that the interests of justice required counsel.”
In re C.B., Juv., 2020 VT 80 (Vt. 2020). “Father also contends that he was improperly denied standing at the merits stage of the CHINS proceeding and was erroneously not granted counsel until after the initial disposition order issued. There is no merit to father’s argument that the court failed to properly assign him…”
In re L.H., L.H. & L.H., Juveniles, 182 A.3d 612 (Vt. 2018). “§ 5112(a) ("The Court shall appoint an attorney for a child who is a party to a proceeding brought under the juvenile judicial proceedings chapters.”
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