Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 5234 (2026)

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

(Cite as: 13 V.S.A. § 5234)
Notes of Decisions
Cited in 21 cases, 1978–2020 · leading case: State v. Fuller, 660 A.2d 302 (Vt. 1995).
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State v. Fuller, 660 A.2d 302 (Vt. 1995). · cites it 16× “It reasoned that the implied consent statute, when read in pari materia with 13 V.S.A. §§ 5234 and 5237 (provisions of the public defender act), required a written waiver of a defendant's right to consult counsel as provided in the implied consent law.”
State v. Picknell, 454 A.2d 711 (Vt. 1982). · cites it 12× “436 (1966), and by 13 V.S.A. § 5234 were *220 violated when the trial court admitted into evidence certain statements made by him; second, whether a court order pursuant to V.”
State v. Robitaille, 2011 VT 135 (Vt. 2011). · cites it 8× “The defendant later argued that his statements must be suppressed because the police failed to obtain a waiver of his right to an attorney “at the precise moment he was arrested” as required by 13 V.S.A. § 5234. Id. at 223, 454 A.2d at 714 .”
State v. Duff, 394 A.2d 1145 (Vt. 1978). · cites it 3× “is not represented by an attorney under conditions in which a person having his own counsel would be entitled to be so represented, the law enforcement officer .”
State v. Hamm, 599 A.2d 1048 (Vt. 1991). · cites it 4× “§ 1202(b) must be read in pari materia with 13 V.S.A. § 5234 of the public defender statute.”
Gilman v. Comm'r of Motor Vehs. & Vermont Dist. Court, Unit No. 3, 583 A.2d 86 (Vt. 1990). · cites it 4× “See 13 V.S.A. § 5234. Since the right to notice of the availability of counsel, 13 V.”
State v. Badger, 450 A.2d 336 (Vt. 1982). “First, he asserted that the initial confession should be suppressed under the fourth, fifth, sixth, and fourteenth amendments of the United States Constitution; the tenth and eleventh articles of the Vermont Constitution; and, under 13 V.S.A. § 5234. Second, he asserted that the…”
State v. Gracey, 436 A.2d 741 (Vt. 1981). · cites it 3× “2d 1145 (1978), we held that this statute must be construed in pari materia with 13 V.S.A. § 5234 of the public defender statute.”
State v. Matthew Webster, 179 A.3d 149 (Vt. 2017). “13 V.S.A. § 5234(a)(2). But contact at the "commencement of detention" does not mean the first thing that a police officer must do upon detaining a defendant is to contact an attorney.”
State v. Pellerin, 637 A.2d 1078 (Vt. 1993). · cites it 5× “The court also concluded that Vermont’s statute providing for a written waiver of the right to counsel, 13 V.S.A. § 5234, had not been violated. Defendant thereafter entered the conditional plea of nolo contendere, and this appeal followed.”
State v. Provost, 896 A.2d 55 (Vt. 2005). “After a person has been detained or charged with a crime, the Act requires that “[ujpon commencement of any later judicial proceeding relating to the same matter, the presiding officer shall clearly inform the person so detained or charged of the right of a needy person to be…”
United States v. Carpentino, 948 F.3d 10 (1st Cir. 2020). “See Vt. Stat. Ann. tit. 13, § 5234 (a). We need not address this claim.”
Show all 21 citing cases →
— Vt. Stat. Ann. tit. 13, § 5234(a) — 7 cases
State v. Picknell, 454 A.2d 711 (Vt. 1982). “436 (1966), and by 13 V.S.A. § 5234 were *220 violated when the trial court admitted into evidence certain statements made by him; second, whether a court order pursuant to V.”
State v. Fuller, 660 A.2d 302 (Vt. 1995). “It reasoned that the implied consent statute, when read in pari materia with 13 V.S.A. §§ 5234 and 5237 (provisions of the public defender act), required a written waiver of a defendant's right to consult counsel as provided in the implied consent law.”
State v. Robitaille, 2011 VT 135 (Vt. 2011). “The defendant later argued that his statements must be suppressed because the police failed to obtain a waiver of his right to an attorney “at the precise moment he was arrested” as required by 13 V.S.A. § 5234. Id. at 223, 454 A.2d at 714 .”
Gilman v. Comm'r of Motor Vehs. & Vermont Dist. Court, Unit No. 3, 583 A.2d 86 (Vt. 1990). “See 13 V.S.A. § 5234. Since the right to notice of the availability of counsel, 13 V.”
State v. Garvey, 595 A.2d 267 (Vt. 1991).
— Vt. Stat. Ann. tit. 13, § 5234(a)(1) — 1 case
State v. Bailey, 682 A.2d 387 (Vt. 1996).
— Vt. Stat. Ann. tit. 13, § 5234(a)(2) — 5 cases
State v. Matthew Webster, 179 A.3d 149 (Vt. 2017). “13 V.S.A. § 5234(a)(2). But contact at the "commencement of detention" does not mean the first thing that a police officer must do upon detaining a defendant is to contact an attorney.”
State v. Robitaille, 2011 VT 135 (Vt. 2011). “The defendant later argued that his statements must be suppressed because the police failed to obtain a waiver of his right to an attorney “at the precise moment he was arrested” as required by 13 V.S.A. § 5234. Id. at 223, 454 A.2d at 714 .”
State v. Picknell, 454 A.2d 711 (Vt. 1982). “436 (1966), and by 13 V.S.A. § 5234 were *220 violated when the trial court admitted into evidence certain statements made by him; second, whether a court order pursuant to V.”
State v. Pellerin, 637 A.2d 1078 (Vt. 1993). “The court also concluded that Vermont’s statute providing for a written waiver of the right to counsel, 13 V.S.A. § 5234, had not been violated. Defendant thereafter entered the conditional plea of nolo contendere, and this appeal followed.”
State v. Jeffreys, 682 A.2d 951 (Vt. 1996).
— Vt. Stat. Ann. tit. 13, § 5234(a)(l) — 1 case
State v. Robitaille, 2011 VT 135 (Vt. 2011). “The defendant later argued that his statements must be suppressed because the police failed to obtain a waiver of his right to an attorney “at the precise moment he was arrested” as required by 13 V.S.A. § 5234. Id. at 223, 454 A.2d at 714 .”
— Vt. Stat. Ann. tit. 13, § 5234(b) — 2 cases
State v. Provost, 896 A.2d 55 (Vt. 2005). “After a person has been detained or charged with a crime, the Act requires that “[ujpon commencement of any later judicial proceeding relating to the same matter, the presiding officer shall clearly inform the person so detained or charged of the right of a needy person to be…”
Fletcher v. Gorczyk, 624 A.2d 1132 (Vt. 1992).
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