Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 204 (2026)

✓ current as of May 2026

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(Cite as: 23 V.S.A. § 204)

§ 204. Surrender of license or registration

(a) A person whose license to operate a motor vehicle, nondriver identification card, or motor vehicle registration has been issued in error shall immediately surrender the license or registration upon demand of the Commissioner or the Commissioner’s authorized inspector or agent. The demand shall be made in person or by notice in writing sent by first-class mail to the last known address of the person.

(b) The Commissioner or the Commissioner’s authorized inspector or agent and all enforcement officers are authorized to take possession of any certificate of title, nondriver identification card, registration, or license issued by this or any other jurisdiction that has been revoked, canceled, or suspended, or that is fictitious, stolen, or altered.

(c) A suspension or revocation shall be deemed to be in effect upon receipt of the notice, if made in person, or three days after the deposit of the notice in the U.S. mail, if made in writing and sent by first-class mail to the last known address of the person.

(d) If a presuspension or prerevocation hearing is available by law, the written notice of suspension or revocation shall so state. Unless otherwise specifically provided by statute, a written request for a hearing must be received at the Department of Motor Vehicles within 15 days after the date of the notice or the right to a hearing is deemed to be waived. (Amended 1983, No. 7; 1989, No. 127 (Adj. Sess.), § 4, eff. Mar. 15, 1990; 1991, No. 164 (Adj. Sess.), § 4; 1993, No. 212 (Adj. Sess.), § 6; 1995, No. 112 (Adj. Sess.), § 2, eff. April 22, 1996; 1999, No. 34, § 4; 2007, No. 61, § 2; 2011, No. 46, § 2; 2023, No. 85 (Adj. Sess.), § 261, eff. July 1, 2024.)

Notes of Decisions

Cited in 8 cases, 1964–2005 · leading case: Perry v. McDonald, 280 F.3d 159 (2d Cir. 2001).

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Perry v. McDonald, 280 F.3d 159 (2d Cir. 2001). · cites it 2× “In addition, the November 3 letter of suspension was governed by Vt. Stat Ann. tit. 23, § 204(a), which provides: (a) A person whose license to operate a motor vehicle, nondriver identification card or whose motor vehicle registration has been issued in error or is suspended or…”

Commonwealth v. Crosscup, 339 N.E.2d 731 (Mass. 1975). “934 (1973); Vt. Stat. Ann. tit. 23, § 204 (1967), State v.”

Boutin v. Conway, 572 A.2d 905 (Vt. 1990). “See 23 V.S.A. § 204 (demand for surrender of license shall be sent to last known address); State v.”

Aiken v. Malloy, 315 A.2d 488 (Vt. 1974). “§ 604, is infirm in that it provides no opportunity for hearing before the commissioner of motor vehicles. Agreeing with this contention would also call into question the procedure for the suspension of operators’ licenses following conviction in a court of law in this State.”

Vermont v. Cattanach, 271 A.2d 828 (Vt. 1970). “The procedure is prescribed in 23 V.S.A. § 204: “A person whose license to operate a motor vehicle, or whose motor vehicle registration is suspended or revoked by the commissioner under the provisions of this title shall surrender forthwith his license or registration upon…”

State v. Hebert, 205 A.2d 816 (Vt. 1964). · cites it 2× “23 V.S.A. §204 provides: “A person whose license to operate a motor vehicle, or whose motor vehicle registration is -suspended or revoked by the commissioner under the provisions of this title shall surrender forthwith his license or registration upon demand of the commissioner…”

State v. Chicoine, 580 A.2d 970 (Vt. 1990). “A person whose license has been suspended may not operate a motor vehicle on a public highway until the commissioner reinstates that right. 23 V.S.A. § 674. Constructive notice of a suspension is sufficient; as long as notice is sent by registered or certified mail to the last…”

Sinha v. Town of Shelburne (Vt. Super. Ct. 2005). “For example, the Department of Motor Vehicles is required to send notice by first class mail to the last known address of a driver whose license is being suspended or revoked.”

— Vt. Stat. Ann. tit. 23, § 204(a) — 2 cases

Perry v. McDonald, 280 F.3d 159 (2d Cir. 2001). “In addition, the November 3 letter of suspension was governed by Vt. Stat Ann. tit. 23, § 204(a), which provides: (a) A person whose license to operate a motor vehicle, nondriver identification card or whose motor vehicle registration has been issued in error or is suspended or…”

Sinha v. Town of Shelburne (Vt. Super. Ct. 2005). “For example, the Department of Motor Vehicles is required to send notice by first class mail to the last known address of a driver whose license is being suspended or revoked.”

— Vt. Stat. Ann. tit. 23, § 204(c) — 1 case

Perry v. McDonald, 280 F.3d 159 (2d Cir. 2001). “In addition, the November 3 letter of suspension was governed by Vt. Stat Ann. tit. 23, § 204(a), which provides: (a) A person whose license to operate a motor vehicle, nondriver identification card or whose motor vehicle registration has been issued in error or is suspended or…”

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