Vt. Stat. Ann. » Title 20 Chapter 113
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 20, § 1923 (2026)

✓ current as of May 2026
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Subchapter 003 : PERSONNEL ADMINISTRATION RULES

(Cite as: 20 V.S.A. § 1923)
Notes of Decisions
Cited in 12 cases (1 in the last 5 years), 1989–2023 · leading case: In Re Grievance of Danforth, 812 A.2d 845 (Vt. 2002).
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In Re Grievance of Danforth, 812 A.2d 845 (Vt. 2002). · cites it 19× “On appeal, the Department argues that the Board lacked jurisdiction to order the Department to disclose IAU records, that those records are confidential under 20 V.S.A. § 1923, and, assuming the Board has jurisdiction, the Board's order was both overbroad and unduly onerous.”
Lay v. Pettengill, Novotny, 2011 VT 127 (Vt. 2011). · cites it 5× “The question of whether an investigation is such that interference with it can constitute obstruction is answered ex ante, not ex post based on what the investigation uncovers.”
Rutland Herald v. Vermont State Police & Off. of the Attorney Gen., 2012 VT 24 (Vt. 2012). · cites it 4× “” 20 V.S.A. § 1923(a). The office of internal affairs within the Department of Public Safety is charged with investigating “all allegations of misconduct by members of the department,” and the head of the internal affairs unit must report all allegations and findings to the…”
Robinson v. State, 730 A.2d 181 (Md. 1999). · cites it 4× “The Department of Public Safety was created by 20 V.S.A. § 1923(b) "to conduct investigations of allegations of misconduct by members of the Department of Public Safety, including the state police.”
Rutland Herald v. City of Rutland & AFSCME Council 93, Local 1201, 2012 VT 26 (Vt. 2012). · cites it 4× “” 20 V.S.A. § 1923(a) (emphasis added). To this end, the office of internal affairs is charged with investigating “all allegations of misconduct by members of the department [of public safety],” and the head of the internal affairs unit must report all allegations and findings…”
State v. Roy, 557 A.2d 884 (Vt. 1989). · cites it 2× “This office was created by 20 V.S.A. § 1923(b) to conduct investigations of allegations of misconduct by members of the Department of Public Safety, including the state police.”
Gregory W. Zullo v. State of Vermont, 205 A.3d 466 (Vt. 2019). “Even if a confidential internal affairs investigation resulted in some disciplinary action against a law enforcement officer, 20 V.S.A. § 1923(d) (providing that records of internal investigation shall be confidential with specific exceptions), it would offer no remedy to…”
F.E.F. v. Cameron, 594 A.2d 897 (Vt. 1991). “However, the disclosure exceptions were very narrow and clearly did not apply in the circumstances for which access was sought.”
Glinka v. Howard Bank, N.A. (In re Powell), 227 B.R. 61 (Bankr. D. Vt. 1998). “§ 1923(d) reads: (d) Records of the office of internal investigation shall be confidential, except: (1) The state police advisory commission shall, at any time, have full and free access to such records; and (2) The commissioner shall deliver such materials from the records of…”
pease v. grinold (Vt. Super. Ct. 2023). · cites it 3× “Because need for the requested discovery has not been shown, the court need not address the legal issue argued by DPS, namely, whether, under the circumstances of this case, discovery is available in view of the provisions of 20 V.S.A. § 1923. The Motion to Quash (MPR #41) is…”
In Re Fef, 594 A.2d 897 (Vt. 1991). “However, the disclosure exceptions were very narrow and clearly did not apply in the circumstances for which access was sought.”
Gregory W. Zullo v. State of Vermont, 2019 VT 1 (Vt. 2019). “Even if a confidential internal affairs investigation resulted in some disciplinary action against a law enforcement officer, 20 V.S.A. § 1923(d) (providing that records of internal investigation shall be confidential with specific exceptions), it would offer no remedy to…”
— Vt. Stat. Ann. tit. 20, § 1923(a) — 4 cases
Rutland Herald v. Vermont State Police & Off. of the Attorney Gen., 2012 VT 24 (Vt. 2012). “” 20 V.S.A. § 1923(a). The office of internal affairs within the Department of Public Safety is charged with investigating “all allegations of misconduct by members of the department,” and the head of the internal affairs unit must report all allegations and findings to the…”
Rutland Herald v. City of Rutland & AFSCME Council 93, Local 1201, 2012 VT 26 (Vt. 2012). “” 20 V.S.A. § 1923(a) (emphasis added). To this end, the office of internal affairs is charged with investigating “all allegations of misconduct by members of the department [of public safety],” and the head of the internal affairs unit must report all allegations and findings…”
F.E.F. v. Cameron, 594 A.2d 897 (Vt. 1991). “However, the disclosure exceptions were very narrow and clearly did not apply in the circumstances for which access was sought.”
In Re Fef, 594 A.2d 897 (Vt. 1991). “However, the disclosure exceptions were very narrow and clearly did not apply in the circumstances for which access was sought.”
— Vt. Stat. Ann. tit. 20, § 1923(b) — 3 cases
Lay v. Pettengill, Novotny, 2011 VT 127 (Vt. 2011). “The question of whether an investigation is such that interference with it can constitute obstruction is answered ex ante, not ex post based on what the investigation uncovers.”
Robinson v. State, 730 A.2d 181 (Md. 1999). “The Department of Public Safety was created by 20 V.S.A. § 1923(b) "to conduct investigations of allegations of misconduct by members of the Department of Public Safety, including the state police.”
State v. Roy, 557 A.2d 884 (Vt. 1989). “This office was created by 20 V.S.A. § 1923(b) to conduct investigations of allegations of misconduct by members of the Department of Public Safety, including the state police.”
— Vt. Stat. Ann. tit. 20, § 1923(c) — 1 case
In Re Grievance of Danforth, 812 A.2d 845 (Vt. 2002). “On appeal, the Department argues that the Board lacked jurisdiction to order the Department to disclose IAU records, that those records are confidential under 20 V.S.A. § 1923, and, assuming the Board has jurisdiction, the Board's order was both overbroad and unduly onerous.”
— Vt. Stat. Ann. tit. 20, § 1923(d) — 9 cases
In Re Grievance of Danforth, 812 A.2d 845 (Vt. 2002). “On appeal, the Department argues that the Board lacked jurisdiction to order the Department to disclose IAU records, that those records are confidential under 20 V.S.A. § 1923, and, assuming the Board has jurisdiction, the Board's order was both overbroad and unduly onerous.”
Rutland Herald v. Vermont State Police & Off. of the Attorney Gen., 2012 VT 24 (Vt. 2012). “” 20 V.S.A. § 1923(a). The office of internal affairs within the Department of Public Safety is charged with investigating “all allegations of misconduct by members of the department,” and the head of the internal affairs unit must report all allegations and findings to the…”
Robinson v. State, 730 A.2d 181 (Md. 1999). “The Department of Public Safety was created by 20 V.S.A. § 1923(b) "to conduct investigations of allegations of misconduct by members of the Department of Public Safety, including the state police.”
Rutland Herald v. City of Rutland & AFSCME Council 93, Local 1201, 2012 VT 26 (Vt. 2012). “” 20 V.S.A. § 1923(a) (emphasis added). To this end, the office of internal affairs is charged with investigating “all allegations of misconduct by members of the department [of public safety],” and the head of the internal affairs unit must report all allegations and findings…”
Gregory W. Zullo v. State of Vermont, 205 A.3d 466 (Vt. 2019). “Even if a confidential internal affairs investigation resulted in some disciplinary action against a law enforcement officer, 20 V.S.A. § 1923(d) (providing that records of internal investigation shall be confidential with specific exceptions), it would offer no remedy to…”
— Vt. Stat. Ann. tit. 20, § 1923(d)(3) — 2 cases
In Re Grievance of Danforth, 812 A.2d 845 (Vt. 2002). “On appeal, the Department argues that the Board lacked jurisdiction to order the Department to disclose IAU records, that those records are confidential under 20 V.S.A. § 1923, and, assuming the Board has jurisdiction, the Board's order was both overbroad and unduly onerous.”
pease v. grinold (Vt. Super. Ct. 2023). “Because need for the requested discovery has not been shown, the court need not address the legal issue argued by DPS, namely, whether, under the circumstances of this case, discovery is available in view of the provisions of 20 V.S.A. § 1923. The Motion to Quash (MPR #41) is…”
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