Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 1038 (2026)

Driving on roadways laned for traffic

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

(Cite as: 23 V.S.A. § 1038)
Notes of Decisions
Cited in 6 cases (3 in the last 5 years), 2011–2025 · leading case: State v. Karen Norton, 2025 VT 56 (Vt. 2025).
State v. Karen Norton, 2025 VT 56 (Vt. 2025). · cites it 2× “2 On appeal, the parties disagree whether the court held that defendant’s driving was a traffic violation under 23 V.S.A. § 1038(1) (“Whenever any roadway has been divided into two or more clearly marked lanes for traffic[,] .”
State v. Michael Sinquell-Gainey & David Vaz, 2022 VT 19 (Vt. 2022). “§ 1031, and failure to maintain the lane of travel during the wide left turn under 23 V.S.A. § 1038. Defendants counter that the trial court correctly determined that the factors Officer LeClair observed did not support a reasonable suspicion that defendants were driving under…”
Michael Sinquell-Gainey & David Vaz, 2022 VT 19 (Vt. 2022). “§ 1031, and failure to maintain the lane of travel during the wide left turn under 23 V.S.A. § 1038. Defendants counter that the trial court correctly determined that the factors Officer LeClair observed did not support a reasonable suspicion that defendants were driving under…”
State v. Raphael Colucci (Vt. 2015). · cites it 5× “The affidavit stated that the officer observed defendant’s vehicle “cross the center line and then the fog line,” in violation of 23 V.S.A. § 1038. For the purposes of the civil suspension, the parties stipulated to admission of the video from the trooper’s cruiser camera.”
State v. Milo Surdam (Vt. 2016). · cites it 2× “The court acknowledged that the video demonstrated that defendant had not actually crossed the double-yellow center line, but concluded nonetheless that the stop was justified because the officer had an objectively reasonable basis for believing that defendant violated 23 V.S.A.…”
State v. Douglas Bedell (Vt. 2011). · cites it 2× “The officer testified that while he was following the vehicle, he observed the vehicle’s tires cross the centerline of the roadway, which he considered a violation of 23 V.S.A. § 1038. The officer stopped defendant, and defendant was subsequently processed for DUI.”
— Vt. Stat. Ann. tit. 23, § 1038(1) — 3 cases
State v. Karen Norton, 2025 VT 56 (Vt. 2025). “2 On appeal, the parties disagree whether the court held that defendant’s driving was a traffic violation under 23 V.S.A. § 1038(1) (“Whenever any roadway has been divided into two or more clearly marked lanes for traffic[,] .”
State v. Milo Surdam (Vt. 2016). “The court acknowledged that the video demonstrated that defendant had not actually crossed the double-yellow center line, but concluded nonetheless that the stop was justified because the officer had an objectively reasonable basis for believing that defendant violated 23 V.S.A.…”
State v. Raphael Colucci (Vt. 2015). “The affidavit stated that the officer observed defendant’s vehicle “cross the center line and then the fog line,” in violation of 23 V.S.A. § 1038. For the purposes of the civil suspension, the parties stipulated to admission of the video from the trooper’s cruiser camera.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.