Vt. Stat. Ann. » Title 18 Chapter 171
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 18, § 7101 (2026)

✓ current as of May 2026
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(Cite as: 18 V.S.A. § 7101)
Notes of Decisions
Cited in 70 cases (3 in the last 5 years), 1971–2024 · leading case: Peck v. Counseling Serv. of Addison Cnty., Inc., 499 A.2d 422 (Vt. 1985).
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Peck v. Counseling Serv. of Addison Cnty., Inc., 499 A.2d 422 (Vt. 1985). · cites it 5× “1984) defines a mental health professional as "a person with professional training, experience and demonstrated competence in the treatment of mental illness, who shall be a physician, psychologist, social worker, nurse or other qualified person designated by the commissioner."…”
In re P.S., 702 A.2d 98 (Vt. 1997). · cites it 3× “” 18 V.S.A. § 7101(16) (emphasis added). To capture the essence of the difference, the parties have often referred to the former standard as one of present dangerousness and the latter standard as one of future dangerousness.”
In re G.G., 2017 VT 10 (Vt. 2017). · cites it 4× “" "A person in need of treatment," in turn, is defined in 18 V.”
United States v. Christopher Perkins, 67 F.4th 583 (4th Cir. 2023). · cites it 4× “§§ 62A-15-602, 62A-15-631 (West 2022); Vt. Stat. Ann. tit. 18, §§ 7101 , 7611 (West 2022); Va.”
In re T.S.S., 121 A.3d 1184 (Vt. 2015). · cites it 10× “argues that the superior court erred in interpreting 18 V.S.A. § 7101(16) and applying it to the evidence.”
In re W. H., 481 A.2d 22 (Vt. 1984). · cites it 4× “35 and 37, order that a proposed patient be physically taken into custody for purposes of obtaining a psychiatric evaluation in order to determine whether the proposed patient is a person “in need of treatment” under 18 V.S.A. § 7101(17) ? The parties have stipulated to the…”
In re G. K., 514 A.2d 1031 (Vt. 1986). · cites it 4× “Each appellee was found to be a patient in need of further treatment, see 18 V.S.A. § 7101(16), and placed under an order of nonhospitalization for an indeterminate period pursuant to 18 V.”
In re L. R., 497 A.2d 753 (Vt. 1985). · cites it 8× “The appellant contends that the State failed to prove, by clear and convincing evidence, that she is a “person in need of treatment,” as defined at 18 V.S.A. § 7101(17), such proof being a prerequisite to an order of involuntary treatment.”
State v. J.S., 817 A.2d 53 (Vt. 2002). · cites it 2× “The court determined that appellant was a person in need of treatment as defined by 18 V.S.A. § 7101(17) and ordered him committed to the state hospital.”
In re E.T., 2004 VT 111 (Vt. 2004). · cites it 2× “” 18 V.S.A. § 7101(16)(B). A “person in need of treatment,” in turn, is “a person who is suffering from mental illness and, as a result of that mental illness, his capacity to exercise self-control, judgment or discretion in the conduct of his affairs and social relations is so…”
Hargrave v. Vermont, 340 F.3d 27 (2d Cir. 2003). · cites it 3× “Defendants argue that, because Act 114 only authorizes state courts to override the DPOAs of individuals who are subject to standing orders of civil commitment, every patient subject to Act 114 poses a “direct threat” of harm to others and, therefore, falls outside the…”
In re T.S.S., 199 Vt. 157 (Vt. 2015). · cites it 9× “argues that the superior court erred in interpreting 18 V.S.A. § 7101(16) and applying it to the evidence.”
Show all 70 citing cases →
— Vt. Stat. Ann. tit. 18, § 7101(11) — 1 case
In Re Marcia R., 383 A.2d 630 (Vt. 1978).
— Vt. Stat. Ann. tit. 18, § 7101(13) — 7 cases
Peck v. Counseling Serv. of Addison Cnty., Inc., 499 A.2d 422 (Vt. 1985). “1984) defines a mental health professional as "a person with professional training, experience and demonstrated competence in the treatment of mental illness, who shall be a physician, psychologist, social worker, nurse or other qualified person designated by the commissioner."…”
In re T. L. S., 481 A.2d 1037 (Vt. 1984).
State v. Curtis, 597 A.2d 770 (Vt. 1991).
In re Jordan, 278 A.2d 724 (Vt. 1971).
In re C.I., 580 A.2d 985 (Vt. 1990).
— Vt. Stat. Ann. tit. 18, § 7101(14) — 6 cases
In re C. B., 518 A.2d 366 (Vt. 1986).
Goodemote v. Scripture, 440 A.2d 150 (Vt. 1981).
In re T.C., 182 Vt. 467 (Vt. 2007).
In Re Cb, 518 A.2d 366 (Vt. 1986).
In Re D.P. (Vt. 2024).
— Vt. Stat. Ann. tit. 18, § 7101(16) — 25 cases
In re T.S.S., 121 A.3d 1184 (Vt. 2015). “argues that the superior court erred in interpreting 18 V.S.A. § 7101(16) and applying it to the evidence.”
In re P.S., 702 A.2d 98 (Vt. 1997). “” 18 V.S.A. § 7101(16) (emphasis added). To capture the essence of the difference, the parties have often referred to the former standard as one of present dangerousness and the latter standard as one of future dangerousness.”
In re G. K., 514 A.2d 1031 (Vt. 1986). “Each appellee was found to be a patient in need of further treatment, see 18 V.S.A. § 7101(16), and placed under an order of nonhospitalization for an indeterminate period pursuant to 18 V.”
In re T.S.S., 199 Vt. 157 (Vt. 2015). “argues that the superior court erred in interpreting 18 V.S.A. § 7101(16) and applying it to the evidence.”
In re G.G., 2017 VT 10 (Vt. 2017). “" "A person in need of treatment," in turn, is defined in 18 V.”
— Vt. Stat. Ann. tit. 18, § 7101(16)(A) — 2 cases
In re G.G., 2017 VT 10 (Vt. 2017). “" "A person in need of treatment," in turn, is defined in 18 V.”
In Re P.K. (Vt. Super. Ct. 2018).
— Vt. Stat. Ann. tit. 18, § 7101(16)(B) — 4 cases
In re E.T., 2004 VT 111 (Vt. 2004). “” 18 V.S.A. § 7101(16)(B). A “person in need of treatment,” in turn, is “a person who is suffering from mental illness and, as a result of that mental illness, his capacity to exercise self-control, judgment or discretion in the conduct of his affairs and social relations is so…”
in re M.C., 2005 VT 60 (Vt. 2005).
In Re Et, 2004 VT 111 (Vt. 2004).
In Re P.K. (Vt. Super. Ct. 2018).
— Vt. Stat. Ann. tit. 18, § 7101(17) — 45 cases
In re W. H., 481 A.2d 22 (Vt. 1984). “35 and 37, order that a proposed patient be physically taken into custody for purposes of obtaining a psychiatric evaluation in order to determine whether the proposed patient is a person “in need of treatment” under 18 V.S.A. § 7101(17) ? The parties have stipulated to the…”
State v. J.S., 817 A.2d 53 (Vt. 2002). “The court determined that appellant was a person in need of treatment as defined by 18 V.S.A. § 7101(17) and ordered him committed to the state hospital.”
In re G.G., 2017 VT 10 (Vt. 2017). “" "A person in need of treatment," in turn, is defined in 18 V.”
State v. Condrick, 477 A.2d 632 (Vt. 1984).
In re G. K., 514 A.2d 1031 (Vt. 1986). “Each appellee was found to be a patient in need of further treatment, see 18 V.S.A. § 7101(16), and placed under an order of nonhospitalization for an indeterminate period pursuant to 18 V.”
— Vt. Stat. Ann. tit. 18, § 7101(17)(A) — 1 case
In re T.H. (Vt. 2016).
— Vt. Stat. Ann. tit. 18, § 7101(17)(A)(i) — 1 case
State v. Robinson, 505 A.2d 674 (Vt. 1986).
— Vt. Stat. Ann. tit. 18, § 7101(17)(A)(ii) — 1 case
In Re D.P. (Vt. 2024).
— Vt. Stat. Ann. tit. 18, § 7101(17)(B)(i) — 2 cases
In re L. R., 497 A.2d 753 (Vt. 1985). “The appellant contends that the State failed to prove, by clear and convincing evidence, that she is a “person in need of treatment,” as defined at 18 V.S.A. § 7101(17), such proof being a prerequisite to an order of involuntary treatment.”
In Re Lr, 497 A.2d 753 (Vt. 1985).
— Vt. Stat. Ann. tit. 18, § 7101(17)(B)(ii) — 2 cases
In re L. R., 497 A.2d 753 (Vt. 1985). “The appellant contends that the State failed to prove, by clear and convincing evidence, that she is a “person in need of treatment,” as defined at 18 V.S.A. § 7101(17), such proof being a prerequisite to an order of involuntary treatment.”
In Re Lr, 497 A.2d 753 (Vt. 1985).
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