Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 1033 (2026)

✓ current as of May 2026
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Subchapter 003 : USE OF ROADWAY

(Cite as: 23 V.S.A. § 1033)
Notes of Decisions
Cited in 6 cases (2 in the last 5 years), 1964–2026 · leading case: Samuel Simblest v. Joseph Maynard, 427 F.2d 1 (2d Cir. 1970).
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Samuel Simblest v. Joseph Maynard, 427 F.2d 1 (2d Cir. 1970). · cites it 3× “” The reason such evidence is critical is that under Vermont law, 23 V.S.A. § 1033, upon the approach of a fire department vehicle which is sounding a siren or displaying a red light, or both, all other vehicles are required to pull over to the right lane of traffic and come to…”
Rochon v. State, 2004 VT 77 (Vt. 2004). · cites it 2× “Before 1973, police cars, ambulances, and fire trucks were granted the right of way over other vehicles, 23 V.S.A. § 1033 (1959 version), and were permitted to ignore speed restrictions as long as they operated their vehicles with due regard for the safety of others, 23 V.”
State v. Marshall, 2010 VT 81 (Vt. 2010). · cites it 2× “As discussed further infra, ¶¶ 5-9, the court's emphasis on the seriousness of defendant's failure to keep right, and on the inferences of crime that could or could not be drawn from it, was an incorrect application of the law, since a lawful stop in this case did not depend on…”
Frank Driscoll v. Wright Cut & Clean, LLC & Benjamin C. Wright, 2024 VT 49 (Vt. 2024). “Ogden’s reference to a four-foot safety gap stems from 23 V.S.A. § 1033(b), which states that a “vehicle approaching or passing a vulnerable user” such as a runner “shall exercise due care, which includes .”
Hebert v. Stanley, 201 A.2d 698 (Vt. 1964). “We would draw attention to that portion of the instructions by which the issue of proximate cause was to be considered by the jury in the event of a finding by them that the defendant had violated the stop sign ordinance.”
Murray v. City of Barre (Vt. Super. Ct. 2026). · cites it 3× “See 23 V.S.A. §§ 1033, 1035, 1039, and 1049. Particularly relevant to the present case, Section 1033(b) requires drivers passing or approaching “vulnerable users” to “exercise due care.”
— Vt. Stat. Ann. tit. 23, § 1033(1) — 1 case
State v. Marshall, 2010 VT 81 (Vt. 2010). “As discussed further infra, ¶¶ 5-9, the court's emphasis on the seriousness of defendant's failure to keep right, and on the inferences of crime that could or could not be drawn from it, was an incorrect application of the law, since a lawful stop in this case did not depend on…”
— Vt. Stat. Ann. tit. 23, § 1033(b) — 2 cases
Frank Driscoll v. Wright Cut & Clean, LLC & Benjamin C. Wright, 2024 VT 49 (Vt. 2024). “Ogden’s reference to a four-foot safety gap stems from 23 V.S.A. § 1033(b), which states that a “vehicle approaching or passing a vulnerable user” such as a runner “shall exercise due care, which includes .”
Murray v. City of Barre (Vt. Super. Ct. 2026). “See 23 V.S.A. §§ 1033, 1035, 1039, and 1049. Particularly relevant to the present case, Section 1033(b) requires drivers passing or approaching “vulnerable users” to “exercise due care.”
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