Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 4 (2026)

✓ current as of May 2026 Cite as: Vt. Stat. Ann. tit. 23, § 4 (2026)
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(Cite as: 23 V.S.A. § 4)
Notes of Decisions
Cited in 40 cases (7 in the last 5 years), 1963–2026 · leading case: State v. Baldwin
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State v. Baldwin (1981) vt · cites it 7× “This is not an unduly strained construction; it places subdivision (12) in harmony, as an operative definition, with the other definitions in 23 V.S.A. § 4, and even more significantly with its opening paragraph which we construe to indicate clearly that the legislature intended…”
Concord General Mutual Insurance v. Woods (2003) vt · cites it 3× “23 V.S.A. § 4(21). Concord General makes much out of the fact that ATVs must be registered if they are driven on public roads.”
State v. Jarvis (1984) vt · cites it 7× “” 23 V.S.A. §§ 4 and 4(13). Although defendant argues that there was no evidence that the Rusty Nail parking lot was open to the public other than the arresting officer’s opinion to that effect, the record does not bear him out.”
State v. LeBlanc (1987) vt · cites it 4× “" The State contends that these statutes grant municipal police officers the power to arrest for violations of Title 23 anywhere in the state.”
State v. Lussier (2000) vt · cites it 2× “§ 1243(a), provides that a motor vehicle shall also be equipped with at least two lighted head lamps of substantially the same intensity and with reflectors and lenses of a design approved by the commissioner of motor vehicles, and with a lighted tail or rear lamp of a design so…”
State v. Hart (1987) vt · cites it 4× “The State contends that 23 V.S.A. §§ 4(11) and 1013 grant constables explicit statewide authority to make arrests for motor vehicle code violations.”
State v. Oliver (1989) vt · cites it 2× “Section 1091(c) imposes criminal penalties on any “person who, while engaged in the violation of any law, ordinance or regulation applying to the operation or use of a motor vehicle or to the regulation of traffic, causes, as a result of the violation, the death of any person .”
State v. Jewett (1987) vt · cites it 2× “III. Defendant also contends that the State failed to prove that he was travelling on a highway, a material element of the offense charged.”
State v. Trucott (1984) vt · cites it 2× “Title 23 V.S.A. § 4(13) defines the relevant terms for purposes of the statutes relating to motor vehicles, and enforcement of the laws regulating vehicles as contained in Title 23, including, therefore, § 1201(a) (2).”
State v. Thompson (2002) vt · cites it 2× “Defendants Rodney Thompson and Leo Hotte argue that since such items of equipment are not defined as “standard equipment” or an element of “properly equipped” under 23 V.S.A. § 4(37), they cannot form the basis for a lawful motor vehicle stop.”
State v. Paquette (1989) vt · cites it 2× “to public or general circulation of vehicles” as required by 23 V.S.A. § 4(13) and § 1201(a)(2). Second, defendant argues that Officer Penniman’s decision to stop the defendant’s vehicle was not supported by reasonable and articulable suspicion.”
Leverson v. Conway (1984) vt · cites it 2× “§§ 8902 (2), 8903 (a), (b), 23 V.S.A. §§ 4 (30), 301. Thus, Vermont’s basic policy is clear: those who use the state’s highways must contribute toward their maintenance and improvement.”
Show all 40 citing cases →
— Vt. Stat. Ann. tit. 23, § 4(11) — 3 cases
State v. LeBlanc (1987) vt “" The State contends that these statutes grant municipal police officers the power to arrest for violations of Title 23 anywhere in the state.”
State v. Hart (1987) vt “The State contends that 23 V.S.A. §§ 4(11) and 1013 grant constables explicit statewide authority to make arrests for motor vehicle code violations.”
State v. Emily K. St. Peter (2018) vt
— Vt. Stat. Ann. tit. 23, § 4(12) — 4 cases
State v. Baldwin (1981) vt “This is not an unduly strained construction; it places subdivision (12) in harmony, as an operative definition, with the other definitions in 23 V.S.A. § 4, and even more significantly with its opening paragraph which we construe to indicate clearly that the legislature intended…”
State v. LeBlanc (1987) vt “" The State contends that these statutes grant municipal police officers the power to arrest for violations of Title 23 anywhere in the state.”
State v. Hart (1987) vt “The State contends that 23 V.S.A. §§ 4(11) and 1013 grant constables explicit statewide authority to make arrests for motor vehicle code violations.”
State v. Griffin (1989) vt
— Vt. Stat. Ann. tit. 23, § 4(13) — 9 cases
State v. Jewett (1987) vt “III. Defendant also contends that the State failed to prove that he was travelling on a highway, a material element of the offense charged.”
State v. Trucott (1984) vt “Title 23 V.S.A. § 4(13) defines the relevant terms for purposes of the statutes relating to motor vehicles, and enforcement of the laws regulating vehicles as contained in Title 23, including, therefore, § 1201(a) (2).”
State v. Paquette (1989) vt “to public or general circulation of vehicles” as required by 23 V.S.A. § 4(13) and § 1201(a)(2). Second, defendant argues that Officer Penniman’s decision to stop the defendant’s vehicle was not supported by reasonable and articulable suspicion.”
State v. McNeil (1995) vt
State v. Jarvis (1984) vt “” 23 V.S.A. §§ 4 and 4(13). Although defendant argues that there was no evidence that the Rusty Nail parking lot was open to the public other than the arresting officer’s opinion to that effect, the record does not bear him out.”
— Vt. Stat. Ann. tit. 23, § 4(19) — 1 case
Pizzagalli Construction Co. v. Town of Whitingham (1986) vt
— Vt. Stat. Ann. tit. 23, § 4(21) — 7 cases
Concord General Mutual Insurance v. Woods (2003) vt “23 V.S.A. § 4(21). Concord General makes much out of the fact that ATVs must be registered if they are driven on public roads.”
State v. Smith (2011) vt
Vt Mutual v. Johnson (2024) vtsuperct
State v. Smith (2011) vt
Town of Brookfield v. Moorcroft (2009) vtsuperct
— Vt. Stat. Ann. tit. 23, § 4(24) — 2 cases
State v. Joseph A. Blanchard (2021) vt
State v. Emmons (2001) vt
— Vt. Stat. Ann. tit. 23, § 4(25) — 1 case
State v. Day (1988)
— Vt. Stat. Ann. tit. 23, § 4(27) — 1 case
State v. Oliver (1989) vt “Section 1091(c) imposes criminal penalties on any “person who, while engaged in the violation of any law, ordinance or regulation applying to the operation or use of a motor vehicle or to the regulation of traffic, causes, as a result of the violation, the death of any person .”
— Vt. Stat. Ann. tit. 23, § 4(30) — 2 cases
Leverson v. Conway (1984) vt “§§ 8902 (2), 8903 (a), (b), 23 V.S.A. §§ 4 (30), 301. Thus, Vermont’s basic policy is clear: those who use the state’s highways must contribute toward their maintenance and improvement.”
Barringer v. Griffes (1992) vtd
— Vt. Stat. Ann. tit. 23, § 4(32) — 1 case
State v. Bailey (1988)
— Vt. Stat. Ann. tit. 23, § 4(37) — 3 cases
State v. Lussier (2000) vt “§ 1243(a), provides that a motor vehicle shall also be equipped with at least two lighted head lamps of substantially the same intensity and with reflectors and lenses of a design approved by the commissioner of motor vehicles, and with a lighted tail or rear lamp of a design so…”
State v. Thompson (2002) vt “Defendants Rodney Thompson and Leo Hotte argue that since such items of equipment are not defined as “standard equipment” or an element of “properly equipped” under 23 V.S.A. § 4(37), they cannot form the basis for a lawful motor vehicle stop.”
State v. Beauregard (2003) vt
— Vt. Stat. Ann. tit. 23, § 4(39) — 1 case
Vt Mutual v. Johnson (2024) vtsuperct
— Vt. Stat. Ann. tit. 23, § 4(44) — 2 cases
Taylor v. Malloy (1980) vt
Meacham v. Conway (1981) vt
— Vt. Stat. Ann. tit. 23, § 4(48)(C) — 1 case
Mooney v. Vt. Dep't of Motor Vehicles (2012) vtsuperct
— Vt. Stat. Ann. tit. 23, § 4(61) — 1 case
Spaulding NOV - Decision on Motion (2024) vtsuperct
— Vt. Stat. Ann. tit. 23, § 4(68) — 1 case
Vt Mutual v. Johnson (2024) vtsuperct
— Vt. Stat. Ann. tit. 23, § 4(7) — 1 case
Bourgon v. Farm Bureau Mutual Insurance Company (1970) vt
— Vt. Stat. Ann. tit. 23, § 4(7)(A) — 1 case
Moody v. Montpelier (2026) vtsuperct
— Vt. Stat. Ann. tit. 23, § 4(70) — 1 case
Vt Mutual v. Johnson (2024) vtsuperct
— Vt. Stat. Ann. tit. 23, § 4(81) — 1 case
Murray v. City of Barre (2026) vtsuperct
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