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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 13, § 7043 (2026)

✓ current as of May 2026
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Subchapter 002 : SENTENCE AND COMMITMENT

(Cite as: 13 V.S.A. § 7043)
Notes of Decisions
Cited in 43 cases (3 in the last 5 years), 1986–2025 · leading case: State v. Bohannon, 2010 VT 22 (Vt. 2010).
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State v. Bohannon, 2010 VT 22 (Vt. 2010). · cites it 12× “2d at 672 ; rather, for the purpose of awarding restitution, we found that the DOC was the "victim" of the defendant's escape under 13 V.S.A. § 7043 and, therefore, entitled to compensation.”
State v. Morse, 2014 VT 84 (Vt. 2014). · cites it 11× “The court issued a written form order, finding: “The victim incurred an uninsured material loss in the total amount of $2427.”
State v. Ty Baker, Sr., 177 A.3d 1093 (Vt. 2017). · cites it 9× “§ 5301(4) ; 13 V.S.A. § 7043. We hold that even if husband was a victim under the restitution statute, his lost wages were not a direct result of defendant's criminal act and therefore fall outside the scope of Vermont's restitution statute, 13 V.”
State v. Randell Blake, 174 A.3d 126 (Vt. 2017). · cites it 5× “(2) For the purposes of this section, "material loss" means uninsured property loss, uninsured out-of-pocket monetary loss, uninsured lost wages, and uninsured medical expenses.”
State v. Jarvis, 509 A.2d 1005 (Vt. 1986). · cites it 8× “Defendant argues that the trial court erred in requiring, as a condition of probation, that defendant pay $5,000.00 restitution to the victim for her pain and suffering because pain and suffering are not proper matters for restitution under 13 V.”
State v. Kenvin, 2011 VT 123 (Vt. 2011). · cites it 5× “The restitution statute, 13 V.S.A. § 7043, sets forth the kinds of losses that may be covered by restitution.”
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018). · cites it 13× “13 V.S.A. § 7043. Before issuing the restitution order, the court must make findings regarding the "amount of the material loss incurred by the victim.”
State v. Gorton, 90 A.3d 901 (Vt. 2014). · cites it 6× “The trial court acknowledged that the State’s request fell outside of the thirty days, but allowed the restitution hearing to go forward based on Vermont’s statutory requirement that restitution be considered in every case in which a victim suffers a material loss, 13 V.”
State v. Shepherd, 2012 VT 91 (Vt. 2012). · cites it 8× “The fact that Juvenile 1’s injury was emotional, however, does not necessarily lead to the dissent’s conclusion that the relocation costs are more like damages for pain and suffering or emotional trauma, which are not proper subjects of restitution under 13 V.S.A. § 7043.…”
State v. Scott, 195 Vt. 330 (Vt. 2013). · cites it 4× “; see also 13 V.S.A. § 7043. We reversed, noting that restitution is available only to the “victim” of a crime, and that “absent any element of injury or harm, the conviction of negligent operation cannot be causally linked to the decedent’s death, and thus cannot support a…”
State v. Hughes, 2010 VT 72 (Vt. 2010). · cites it 5× “Specifically defendant suggests that the trial court erred by placing the burden of proving the store was not insured on him and by improperly ignoring evidence that the store’s form of self-insurance precluded restitution under the statute.”
State v. Scott, 2013 VT 103 (Vt. 2013). · cites it 4× “; see also 13 V.S.A. § 7043. We reversed, noting that restitution is available only to the “victim” of a crime, and that “absent any element of injury or harm, the conviction of negligent operation cannot be causally linked to the decedent’s death, and thus cannot support a…”
Show all 43 citing cases →
— Vt. Stat. Ann. tit. 13, § 7043(a) — 7 cases
State v. May, 689 A.2d 1075 (Vt. 1996).
State v. Bohannon, 2010 VT 22 (Vt. 2010). “2d at 672 ; rather, for the purpose of awarding restitution, we found that the DOC was the "victim" of the defendant's escape under 13 V.S.A. § 7043 and, therefore, entitled to compensation.”
State v. Morse, 2014 VT 84 (Vt. 2014). “The court issued a written form order, finding: “The victim incurred an uninsured material loss in the total amount of $2427.”
State v. VanDusen, 691 A.2d 1053 (Vt. 1997).
State v. Thomas, 2010 VT 107 (Vt. 2010).
— Vt. Stat. Ann. tit. 13, § 7043(a)(1) — 22 cases
State v. Bohannon, 2010 VT 22 (Vt. 2010). “2d at 672 ; rather, for the purpose of awarding restitution, we found that the DOC was the "victim" of the defendant's escape under 13 V.S.A. § 7043 and, therefore, entitled to compensation.”
State v. Morse, 2014 VT 84 (Vt. 2014). “The court issued a written form order, finding: “The victim incurred an uninsured material loss in the total amount of $2427.”
State v. Shepherd, 2012 VT 91 (Vt. 2012). “The fact that Juvenile 1’s injury was emotional, however, does not necessarily lead to the dissent’s conclusion that the relocation costs are more like damages for pain and suffering or emotional trauma, which are not proper subjects of restitution under 13 V.S.A. § 7043.…”
State v. Driscoll, 2008 VT 101 (Vt. 2008).
State v. Hughes, 2010 VT 72 (Vt. 2010). “Specifically defendant suggests that the trial court erred by placing the burden of proving the store was not insured on him and by improperly ignoring evidence that the store’s form of self-insurance precluded restitution under the statute.”
— Vt. Stat. Ann. tit. 13, § 7043(a)(2) — 12 cases
State v. Randell Blake, 174 A.3d 126 (Vt. 2017). “(2) For the purposes of this section, "material loss" means uninsured property loss, uninsured out-of-pocket monetary loss, uninsured lost wages, and uninsured medical expenses.”
Garrett M. Cornelius v. The Chronicle, Inc., 206 A.3d 710 (Vt. 2019).
State v. Kenvin, 2011 VT 123 (Vt. 2011). “The restitution statute, 13 V.S.A. § 7043, sets forth the kinds of losses that may be covered by restitution.”
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018). “13 V.S.A. § 7043. Before issuing the restitution order, the court must make findings regarding the "amount of the material loss incurred by the victim.”
State v. Ty Baker, Sr., 177 A.3d 1093 (Vt. 2017). “§ 5301(4) ; 13 V.S.A. § 7043. We hold that even if husband was a victim under the restitution statute, his lost wages were not a direct result of defendant's criminal act and therefore fall outside the scope of Vermont's restitution statute, 13 V.”
— Vt. Stat. Ann. tit. 13, § 7043(a)(l) — 2 cases
State v. Morse, 2014 VT 84 (Vt. 2014). “The court issued a written form order, finding: “The victim incurred an uninsured material loss in the total amount of $2427.”
State v. Shepherd, 2012 VT 91 (Vt. 2012). “The fact that Juvenile 1’s injury was emotional, however, does not necessarily lead to the dissent’s conclusion that the relocation costs are more like damages for pain and suffering or emotional trauma, which are not proper subjects of restitution under 13 V.S.A. § 7043.…”
— Vt. Stat. Ann. tit. 13, § 7043(b) — 1 case
State v. Jarvis, 509 A.2d 1005 (Vt. 1986). “Defendant argues that the trial court erred in requiring, as a condition of probation, that defendant pay $5,000.00 restitution to the victim for her pain and suffering because pain and suffering are not proper matters for restitution under 13 V.”
— Vt. Stat. Ann. tit. 13, § 7043(b)(1) — 1 case
State v. Lewis, 711 A.2d 669 (Vt. 1998).
— Vt. Stat. Ann. tit. 13, § 7043(c) — 3 cases
State v. Hughes, 2010 VT 72 (Vt. 2010). “Specifically defendant suggests that the trial court erred by placing the burden of proving the store was not insured on him and by improperly ignoring evidence that the store’s form of self-insurance precluded restitution under the statute.”
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018). “13 V.S.A. § 7043. Before issuing the restitution order, the court must make findings regarding the "amount of the material loss incurred by the victim.”
State v. Lucas Dwight, 2018 VT 73 (Vt. 2018).
— Vt. Stat. Ann. tit. 13, § 7043(c)(1) — 1 case
State v. Randell Blake, 174 A.3d 126 (Vt. 2017). “(2) For the purposes of this section, "material loss" means uninsured property loss, uninsured out-of-pocket monetary loss, uninsured lost wages, and uninsured medical expenses.”
— Vt. Stat. Ann. tit. 13, § 7043(c)(2) — 2 cases
State v. Kenvin, 2011 VT 123 (Vt. 2011). “The restitution statute, 13 V.S.A. § 7043, sets forth the kinds of losses that may be covered by restitution.”
State v. Ty Baker, Sr., 177 A.3d 1093 (Vt. 2017). “§ 5301(4) ; 13 V.S.A. § 7043. We hold that even if husband was a victim under the restitution statute, his lost wages were not a direct result of defendant's criminal act and therefore fall outside the scope of Vermont's restitution statute, 13 V.”
— Vt. Stat. Ann. tit. 13, § 7043(c)(3) — 1 case
State v. Morse, 2014 VT 84 (Vt. 2014). “The court issued a written form order, finding: “The victim incurred an uninsured material loss in the total amount of $2427.”
— Vt. Stat. Ann. tit. 13, § 7043(d) — 2 cases
State v. Vezina, 2015 VT 56 (Vt. 2015).
State v. Vezina, 199 Vt. 175 (Vt. 2015).
— Vt. Stat. Ann. tit. 13, § 7043(d)(1) — 2 cases
State v. Ty Baker, Sr., 177 A.3d 1093 (Vt. 2017). “§ 5301(4) ; 13 V.S.A. § 7043. We hold that even if husband was a victim under the restitution statute, his lost wages were not a direct result of defendant's criminal act and therefore fall outside the scope of Vermont's restitution statute, 13 V.”
State v. Morse, 2014 VT 84 (Vt. 2014). “The court issued a written form order, finding: “The victim incurred an uninsured material loss in the total amount of $2427.”
— Vt. Stat. Ann. tit. 13, § 7043(d)(2) — 7 cases
State v. Ty Baker, Sr., 177 A.3d 1093 (Vt. 2017). “§ 5301(4) ; 13 V.S.A. § 7043. We hold that even if husband was a victim under the restitution statute, his lost wages were not a direct result of defendant's criminal act and therefore fall outside the scope of Vermont's restitution statute, 13 V.”
State v. Vezina, 2015 VT 56 (Vt. 2015).
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018). “13 V.S.A. § 7043. Before issuing the restitution order, the court must make findings regarding the "amount of the material loss incurred by the victim.”
State v. Gorton, 90 A.3d 901 (Vt. 2014). “The trial court acknowledged that the State’s request fell outside of the thirty days, but allowed the restitution hearing to go forward based on Vermont’s statutory requirement that restitution be considered in every case in which a victim suffers a material loss, 13 V.”
State v. Vezina, 199 Vt. 175 (Vt. 2015).
— Vt. Stat. Ann. tit. 13, § 7043(e)(1) — 3 cases
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018). “13 V.S.A. § 7043. Before issuing the restitution order, the court must make findings regarding the "amount of the material loss incurred by the victim.”
State v. Lucas Dwight, 2018 VT 73 (Vt. 2018).
State v. Tiffany Marcotte (Vt. 2013).
— Vt. Stat. Ann. tit. 13, § 7043(e)(3) — 4 cases
State v. Gorton, 90 A.3d 901 (Vt. 2014). “The trial court acknowledged that the State’s request fell outside of the thirty days, but allowed the restitution hearing to go forward based on Vermont’s statutory requirement that restitution be considered in every case in which a victim suffers a material loss, 13 V.”
State v. Vezina, 2015 VT 56 (Vt. 2015).
State v. Vezina, 199 Vt. 175 (Vt. 2015).
State v. Raymond Ritchie (Vt. 2019).
— Vt. Stat. Ann. tit. 13, § 7043(g) — 2 cases
Langle v. Kurkul, 510 A.2d 1301 (Vt. 1986).
State v. Jarvis, 509 A.2d 1005 (Vt. 1986). “Defendant argues that the trial court erred in requiring, as a condition of probation, that defendant pay $5,000.00 restitution to the victim for her pain and suffering because pain and suffering are not proper matters for restitution under 13 V.”
— Vt. Stat. Ann. tit. 13, § 7043(g)(2)(A) — 1 case
State v. Gorton, 90 A.3d 901 (Vt. 2014). “The trial court acknowledged that the State’s request fell outside of the thirty days, but allowed the restitution hearing to go forward based on Vermont’s statutory requirement that restitution be considered in every case in which a victim suffers a material loss, 13 V.”
— Vt. Stat. Ann. tit. 13, § 7043(h) — 3 cases
State v. Randell Blake, 174 A.3d 126 (Vt. 2017). “(2) For the purposes of this section, "material loss" means uninsured property loss, uninsured out-of-pocket monetary loss, uninsured lost wages, and uninsured medical expenses.”
State v. Morse, 2014 VT 84 (Vt. 2014). “The court issued a written form order, finding: “The victim incurred an uninsured material loss in the total amount of $2427.”
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018). “13 V.S.A. § 7043. Before issuing the restitution order, the court must make findings regarding the "amount of the material loss incurred by the victim.”
— Vt. Stat. Ann. tit. 13, § 7043(h)(2) — 2 cases
State v. Kenvin, 2011 VT 123 (Vt. 2011). “The restitution statute, 13 V.S.A. § 7043, sets forth the kinds of losses that may be covered by restitution.”
State v. Thomas, 2010 VT 107 (Vt. 2010).
— Vt. Stat. Ann. tit. 13, § 7043(i)(2) — 1 case
State v. Frank Fellows (Vt. 2013).
— Vt. Stat. Ann. tit. 13, § 7043(l) — 2 cases
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018). “13 V.S.A. § 7043. Before issuing the restitution order, the court must make findings regarding the "amount of the material loss incurred by the victim.”
State v. Lucas Dwight, 2018 VT 73 (Vt. 2018).
— Vt. Stat. Ann. tit. 13, § 7043(o) — 2 cases
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018). “13 V.S.A. § 7043. Before issuing the restitution order, the court must make findings regarding the "amount of the material loss incurred by the victim.”
State v. Lucas Dwight, 2018 VT 73 (Vt. 2018).
— Vt. Stat. Ann. tit. 13, § 7043(p) — 2 cases
State v. Ty Baker, Sr., 177 A.3d 1093 (Vt. 2017). “§ 5301(4) ; 13 V.S.A. § 7043. We hold that even if husband was a victim under the restitution statute, his lost wages were not a direct result of defendant's criminal act and therefore fall outside the scope of Vermont's restitution statute, 13 V.”
State v. Randy F. Therrien, 2022 VT 35 (Vt. 2022).
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