Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 304 (2026)

✓ current as of May 2026
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Subchapter 001 : GENERAL REGISTRATION

(Cite as: 23 V.S.A. § 304)
Notes of Decisions
Cited in 11 cases, 1978–2019 · leading case: Martin v. State, Dept. of Motor Vehs., 2003 VT 14 (Vt. 2003).
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Martin v. State, Dept. of Motor Vehs., 2003 VT 14 (Vt. 2003). · cites it 11× “Here, the Legislature has given the Commissioner the general authority to assign a combination of numbers and letters for each registered motor vehicle, see 23 V.S.A. § 304(a), and to issue vanity plates and specialty plates for safety or service organizations, see id.”
Byrne v. Rutledge, 623 F.3d 46 (2d Cir. 2010). · cites it 4× “” Vt. Stat. Ann. tit. 23, § 304 (d)(4). In April 2004, plaintiff-appellant Shawn Byrne applied for plate “JN36TN,” which he intended as a reference to the often-quoted Biblical verse, John 3:16.”
Perry v. McDonald, 280 F.3d 159 (2d Cir. 2001). · cites it 5× “” Vt. Stat. Ann. tit. 23, § 304 (d). 1 Here, Perry requested vanity plates bearing the letters “SHTHPNS,” which stand for “Shit Happens.”
Gregory W. Zullo v. State of Vermont, 205 A.3d 466 (Vt. 2019). “3d 883 (stating that "all of the mandates of § 511 governing the manner of display of license plates are related to visibility and readability of the plate"); see also 23 V.S.A. § 304(b)(2)(B) ("[T]he primary purpose of motor vehicle number plates is vehicle identification.”
Child. First Found., Inc. v. Fiala, 790 F.3d 328 (2d Cir. 2015). “3d at 49 (quoting Vt.Stat. Ann. Tit. 23, § 304(d)(1), (3)(A)).”
Lague, Inc. v. State, 392 A.2d 942 (Vt. 1978). · cites it 3× “The court dismissed the action on the merits, ruling that the Department of Motor Vehicles followed a duly promulgated regulation, that the Commissioner, had the statutory authority under 23 V.S.A. § 304 to issue the regulation, that issuance of low number plates to prior…”
State v. Tuma, 2013 VT 70 (Vt. 2013). “While we agree that that might be a reasonable interpretation of the statute, we decline to make such a specific mathematical ruling.”
Gregory W. Zullo v. State of Vermont, 2019 VT 1 (Vt. 2019). “See Tuma, 2013 VT 70, ¶ 12 (stating that “all of the mandates of § 511 governing the manner of display of license plates are related to visibility and readability of the plate”); see also 23 V.S.A. § 304(b)(2)(B) (“[T]he primary purpose of motor vehicle number plates is vehicle…”
Rex v. Martinez (2d Cir. 2015). “3d at 49 (quoting 17 Vt. Stat. Ann. Tit. 23, § 304(d)(1), (3)(A)).”
Rex v. Martinez (2d Cir. 2015). “3d at 49 (quoting 17 Vt. Stat. Ann. Tit. 23, § 304(d)(1), (3)(A)).”
Intervale Ctr., Inc. & Half Pint Farm (Hoop House) (Vt. Super. Ct. 2009). “at ¶ 2 (alteration in original) (citing 23 V.S.A. § 304(d)6). The DMV issued regulations that banned certain categories of license plates (including ones like “IRISH”).”
— Vt. Stat. Ann. tit. 23, § 304(a) — 1 case
Martin v. State, Dept. of Motor Vehs., 2003 VT 14 (Vt. 2003). “Here, the Legislature has given the Commissioner the general authority to assign a combination of numbers and letters for each registered motor vehicle, see 23 V.S.A. § 304(a), and to issue vanity plates and specialty plates for safety or service organizations, see id.”
— Vt. Stat. Ann. tit. 23, § 304(b)(2)(B) — 3 cases
Gregory W. Zullo v. State of Vermont, 205 A.3d 466 (Vt. 2019). “3d 883 (stating that "all of the mandates of § 511 governing the manner of display of license plates are related to visibility and readability of the plate"); see also 23 V.S.A. § 304(b)(2)(B) ("[T]he primary purpose of motor vehicle number plates is vehicle identification.”
State v. Tuma, 2013 VT 70 (Vt. 2013). “While we agree that that might be a reasonable interpretation of the statute, we decline to make such a specific mathematical ruling.”
Gregory W. Zullo v. State of Vermont, 2019 VT 1 (Vt. 2019). “See Tuma, 2013 VT 70, ¶ 12 (stating that “all of the mandates of § 511 governing the manner of display of license plates are related to visibility and readability of the plate”); see also 23 V.S.A. § 304(b)(2)(B) (“[T]he primary purpose of motor vehicle number plates is vehicle…”
— Vt. Stat. Ann. tit. 23, § 304(c) — 1 case
Lague, Inc. v. State, 392 A.2d 942 (Vt. 1978). “The court dismissed the action on the merits, ruling that the Department of Motor Vehicles followed a duly promulgated regulation, that the Commissioner, had the statutory authority under 23 V.S.A. § 304 to issue the regulation, that issuance of low number plates to prior…”
— Vt. Stat. Ann. tit. 23, § 304(d) — 3 cases
Martin v. State, Dept. of Motor Vehs., 2003 VT 14 (Vt. 2003). “Here, the Legislature has given the Commissioner the general authority to assign a combination of numbers and letters for each registered motor vehicle, see 23 V.S.A. § 304(a), and to issue vanity plates and specialty plates for safety or service organizations, see id.”
Perry v. McDonald, 280 F.3d 159 (2d Cir. 2001). “” Vt. Stat. Ann. tit. 23, § 304 (d). 1 Here, Perry requested vanity plates bearing the letters “SHTHPNS,” which stand for “Shit Happens.”
Intervale Ctr., Inc. & Half Pint Farm (Hoop House) (Vt. Super. Ct. 2009). “at ¶ 2 (alteration in original) (citing 23 V.S.A. § 304(d)6). The DMV issued regulations that banned certain categories of license plates (including ones like “IRISH”).”
— Vt. Stat. Ann. tit. 23, § 304(d)(1) — 3 cases
Child. First Found., Inc. v. Fiala, 790 F.3d 328 (2d Cir. 2015). “3d at 49 (quoting Vt.Stat. Ann. Tit. 23, § 304(d)(1), (3)(A)).”
Rex v. Martinez (2d Cir. 2015). “3d at 49 (quoting 17 Vt. Stat. Ann. Tit. 23, § 304(d)(1), (3)(A)).”
Rex v. Martinez (2d Cir. 2015). “3d at 49 (quoting 17 Vt. Stat. Ann. Tit. 23, § 304(d)(1), (3)(A)).”
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