Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 5241 (2026)

Ineffective assistance claim

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

(Cite as: 13 V.S.A. § 5241)
Notes of Decisions
Cited in 6 cases (3 in the last 5 years), 2017–2026 · leading case: Stephan Palmer, Sr. v. Mark Furlan & State of Vermont, 2019 VT 42 (Vt. 2019).
Stephan Palmer, Sr. v. Mark Furlan & State of Vermont, 2019 VT 42 (Vt. 2019). · cites it 5× “After discovery, Attorney Furlan moved for summary judgment on the grounds that: (1) Attorney Furlan was statutorily immune from appellant’s claims under 13 V.S.A. § 5241; 1 Appellant also filed suit against the State of Vermont, on the theory that “[b]y the terms of 13 V.”
palmer v. furlan (Vt. Super. Ct. 2024). · cites it 5× “Furlan and, separately, against the State pursuant to 13 V.S.A. § 5241(b). In addition, he claims gross negligence and willful misconduct against Mr.”
Palmer v. Furlan (Vt. Super. Ct. 2017). · cites it 5× “Furlan and, separately, against the State pursuant to 13 V.S.A. § 5241(b). In addition, he claims gross negligence and willful misconduct against Mr.”
palmer v. furlan (Vt. Super. Ct. 2024). · cites it 4× “Furlan has filed a motion for summary judgment arguing that he is statutorily” immune from suit 13 V.S.A. § 5241(b) and that there is no evidentiary basis for any element of a negligence claim.”
Palmer v. Furlan (Vt. Super. Ct. 2018). · cites it 4× “Attorney Furlan was an ad hoc defender—an independent contractor with the State rather than its employee—when he represented Mr. Palmer in his PCR case.”
Scanlon v. State (Vt. Super. Ct. 2026). “First, pursuant to 13 V.S.A. § 5241(b), no ineffective assistance of counsel claim can be filed unless and until the plaintiff has prevailed in a claim for postconviction relief based on ineffective assistance of counsel.”
— Vt. Stat. Ann. tit. 13, § 5241(a) — 1 case
Stephan Palmer, Sr. v. Mark Furlan & State of Vermont, 2019 VT 42 (Vt. 2019). “After discovery, Attorney Furlan moved for summary judgment on the grounds that: (1) Attorney Furlan was statutorily immune from appellant’s claims under 13 V.S.A. § 5241; 1 Appellant also filed suit against the State of Vermont, on the theory that “[b]y the terms of 13 V.”
— Vt. Stat. Ann. tit. 13, § 5241(b) — 6 cases
Stephan Palmer, Sr. v. Mark Furlan & State of Vermont, 2019 VT 42 (Vt. 2019). “After discovery, Attorney Furlan moved for summary judgment on the grounds that: (1) Attorney Furlan was statutorily immune from appellant’s claims under 13 V.S.A. § 5241; 1 Appellant also filed suit against the State of Vermont, on the theory that “[b]y the terms of 13 V.”
palmer v. furlan (Vt. Super. Ct. 2024). “Furlan and, separately, against the State pursuant to 13 V.S.A. § 5241(b). In addition, he claims gross negligence and willful misconduct against Mr.”
Palmer v. Furlan (Vt. Super. Ct. 2017). “Furlan and, separately, against the State pursuant to 13 V.S.A. § 5241(b). In addition, he claims gross negligence and willful misconduct against Mr.”
palmer v. furlan (Vt. Super. Ct. 2024). “Furlan has filed a motion for summary judgment arguing that he is statutorily” immune from suit 13 V.S.A. § 5241(b) and that there is no evidentiary basis for any element of a negligence claim.”
Palmer v. Furlan (Vt. Super. Ct. 2018). “Attorney Furlan was an ad hoc defender—an independent contractor with the State rather than its employee—when he represented Mr. Palmer in his PCR case.”
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