Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 1064 (2026)

Signals required; general obligation to turn and move safely

✓ current as of May 2026
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Subchapter 006 : TURNING AND STARTING AND SIGNALS ON STOPPING AND TURNING

(Cite as: 23 V.S.A. § 1064)
Notes of Decisions
Cited in 10 cases (2 in the last 5 years), 1992–2022 · leading case: State v. Sutphin, 614 A.2d 792 (Vt. 1992).
State v. Sutphin, 614 A.2d 792 (Vt. 1992). · cites it 4× “The plurality opinion concludes that, because defendant used her right turn signal *799 before she pulled off the road, she violated a rule of the road, 23 V.S.A. § 1064(e). Section 1064 (Signals required), provides The signals provided for in section 1065 of this title shall be…”
State v. Harris, 2009 VT 73 (Vt. 2009). · cites it 2× “” 23 V.S.A. § 1064(a). According to the court’s reasoning, when the state trooper observed defendant exit the rotary without signaling, the trooper had a reasonable and articulable suspicion that defendant violated a motor vehicle law, which was sufficient to justify the stop.”
State v. Fletcher, 2010 VT 27 (Vt. 2010). “At that point, the state trooper pulled defendant over for violating 23 V.S.A. § 1064(d), which requires drivers to continuously signal their intention to turn for at least one hundred feet prior to turning.”
State v. Kevin W. Cook, 203 A.3d 509 (Vt. 2018). · cites it 3× “During the traffic stop, the officer smelled alcohol on defendant and conducted field-sobriety tests.”
State v. Anthony Brunetta, 2020 VT 109 (Vt. 2020). · cites it 3× “At the close of evidence, defendant argued, among other things, that there was no legal basis for the stop because the State had failed to meet its burden of showing that defendant did not use a hand signal before turning—an option allowed under 23 V.S.A. § 1064(a). Id.…”
State v. Hutchins, 2015 VT 38 (Vt. 2015). · cites it 2× “The State raised only one potential violation — of 23 V.S.A. § 1064(d), “Signals required” — before the trial court, and proclaimed at oral argument that the only issue in this case is whether defendant made a “turn” for purposes of § 1064(d).”
State v. Johnson, 148 S.W.3d 338 (Mo. Ct. App. 2004). “104 (a) (1999); Vermont: Vt. Stat. Ann. tit. 23 § 1064. 3 . The court did not identify those cases.”
State v. Michael Sinquell-Gainey & David Vaz, 2022 VT 19 (Vt. 2022). · cites it 4× “See 23 V.S.A. § 1064(d). He also testified that the driver “stopped for quite some time,” even though no stop was required.”
Michael Sinquell-Gainey & David Vaz, 2022 VT 19 (Vt. 2022). · cites it 4× “See 23 V.S.A. § 1064(d). He also testified that the driver “stopped for quite some time,” even though no stop was required.”
State v. Dzina Brakarenka (Vt. 2016). “See 23 V.S.A. § 1064(d) (providing that driver must signal his or her intention to turn right or left “continuously during not less than the last 100 feet traveled by the vehicle before turning”).”
— Vt. Stat. Ann. tit. 23, § 1064(a) — 3 cases
State v. Harris, 2009 VT 73 (Vt. 2009). “” 23 V.S.A. § 1064(a). According to the court’s reasoning, when the state trooper observed defendant exit the rotary without signaling, the trooper had a reasonable and articulable suspicion that defendant violated a motor vehicle law, which was sufficient to justify the stop.”
State v. Anthony Brunetta, 2020 VT 109 (Vt. 2020). “At the close of evidence, defendant argued, among other things, that there was no legal basis for the stop because the State had failed to meet its burden of showing that defendant did not use a hand signal before turning—an option allowed under 23 V.S.A. § 1064(a). Id.…”
State v. Kevin W. Cook, 203 A.3d 509 (Vt. 2018). “During the traffic stop, the officer smelled alcohol on defendant and conducted field-sobriety tests.”
— Vt. Stat. Ann. tit. 23, § 1064(d) — 5 cases
State v. Fletcher, 2010 VT 27 (Vt. 2010). “At that point, the state trooper pulled defendant over for violating 23 V.S.A. § 1064(d), which requires drivers to continuously signal their intention to turn for at least one hundred feet prior to turning.”
State v. Hutchins, 2015 VT 38 (Vt. 2015). “The State raised only one potential violation — of 23 V.S.A. § 1064(d), “Signals required” — before the trial court, and proclaimed at oral argument that the only issue in this case is whether defendant made a “turn” for purposes of § 1064(d).”
State v. Michael Sinquell-Gainey & David Vaz, 2022 VT 19 (Vt. 2022). “See 23 V.S.A. § 1064(d). He also testified that the driver “stopped for quite some time,” even though no stop was required.”
Michael Sinquell-Gainey & David Vaz, 2022 VT 19 (Vt. 2022). “See 23 V.S.A. § 1064(d). He also testified that the driver “stopped for quite some time,” even though no stop was required.”
State v. Dzina Brakarenka (Vt. 2016). “See 23 V.S.A. § 1064(d) (providing that driver must signal his or her intention to turn right or left “continuously during not less than the last 100 feet traveled by the vehicle before turning”).”
— Vt. Stat. Ann. tit. 23, § 1064(e) — 2 cases
State v. Sutphin, 614 A.2d 792 (Vt. 1992). “The plurality opinion concludes that, because defendant used her right turn signal *799 before she pulled off the road, she violated a rule of the road, 23 V.S.A. § 1064(e). Section 1064 (Signals required), provides The signals provided for in section 1065 of this title shall be…”
State v. Harris, 2009 VT 73 (Vt. 2009). “” 23 V.S.A. § 1064(a). According to the court’s reasoning, when the state trooper observed defendant exit the rotary without signaling, the trooper had a reasonable and articulable suspicion that defendant violated a motor vehicle law, which was sufficient to justify the stop.”
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