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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 674 (2026)

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Subchapter 003 : SUSPENSION AND REVOCATION

(Cite as: 23 V.S.A. § 674)
Notes of Decisions
Cited in 60 cases (1 in the last 5 years), 1964–2021 · leading case: State v. Saari, 568 A.2d 344 (Vt. 1989).
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State v. Saari, 568 A.2d 344 (Vt. 1989). · cites it 14× “See 23 V.S.A. § 674 (present subsection (a), rewritten in 1981, sets penalty for the first DLS offense at thirty days and/or $500); 13 V.”
State v. Longe, 743 A.2d 569 (Vt. 1999). · cites it 17× “In the instant case, § 674(b) establishes a maximum of two years imprisonment, a fine of $5,000, or both, if the underlying suspension was a result of a violation of § 1201.”
State v. Cady, 383 A.2d 607 (Vt. 1978). · cites it 16× “23 V.S.A. § 674. [3] To sustain a violation of § 674, three elements must be proven: (1) suspension; (2) no reinstatement; and (3) operation.”
State v. Bradley, 494 A.2d 129 (Vt. 1985). · cites it 8× “The defendant, Dawn Bradley, was charged with driving a motor vehicle while under license suspension in violation of 23 V.S.A. § 674. The defendant pleaded guilty to the charge pursuant to a plea agreement made with the prosecutor.”
State v. Baker, 579 A.2d 479 (Vt. 1990). · cites it 5× “Defendant appeals from a jury conviction of operating a motor vehicle while his license was suspended (DLS), in violation of 23 V.S.A. § 674(a). He alleges two errors: (1) the trial court placed the burden of proving the necessity defense upon him rather than requiring the State…”
State v. Porter, 671 A.2d 1280 (Vt. 1996). · cites it 4× “Lafountain involved a sentence enhancement for third-offense driving with license suspended, 23 V.S.A. § 674(b), in which the first offense is a civil violation carrying no prison sentence.”
State v. Jarvis, 482 A.2d 65 (Vt. 1984). · cites it 8× “), 23 V.S.A. § 674. Both offenses were alleged to have occurred in the parking lot of a restaurant, known as the Rusty Nail, in Stowe, Vermont.”
In Re Miller, 2009 VT 36 (Vt. 2009). · cites it 2× “§ 1210(d), carrying a maximum penalty of five years and/or a fine of $2,500; (2) one count of DLS-2, 23 V.S.A. § 674(b), carrying a maximum penalty of two years and/or a fine of $5,000; (3) one count of giving false information to a police officer, 13 V.”
State v. Cunningham, 2008 VT 43 (Vt. 2008). · cites it 2× “[5] *1296 III. May 5, 2005 ¶ 19. The initial traffic stop on May 5 was justified, as defendant concedes, by the officer's knowledge that defendant's license was suspended.”
State v. Billy Joe Putnam, 2015 VT 113 (Vt. 2015). · cites it 2× “, 23 V.S.A. § 674, and a civil violation in other circumstances, see id.”
State v. Flagg, 624 A.2d 864 (Vt. 1993). · cites it 5× “On August 22, 1991, defendant was charged with violating 23 V.S.A. § 674 as it existed at the time of defendant’s conduct.”
State v. Millette, 795 A.2d 1182 (Vt. 2002). · cites it 3× “A § 1711; (3) driving when his license had been suspended for DUI in Windsor County, in violation of 23 V.S.A. § 674(b); (4) driving when his license had been suspended for DUI from Bennington to Windham, in violation of 23 V.”
Show all 60 citing cases →
— Vt. Stat. Ann. tit. 23, § 674(a) — 12 cases
State v. Cunningham, 2008 VT 43 (Vt. 2008). “[5] *1296 III. May 5, 2005 ¶ 19. The initial traffic stop on May 5 was justified, as defendant concedes, by the officer's knowledge that defendant's license was suspended.”
State v. Saari, 568 A.2d 344 (Vt. 1989). “See 23 V.S.A. § 674 (present subsection (a), rewritten in 1981, sets penalty for the first DLS offense at thirty days and/or $500); 13 V.”
State v. Baker, 579 A.2d 479 (Vt. 1990). “Defendant appeals from a jury conviction of operating a motor vehicle while his license was suspended (DLS), in violation of 23 V.S.A. § 674(a). He alleges two errors: (1) the trial court placed the burden of proving the necessity defense upon him rather than requiring the State…”
State v. Bradley, 494 A.2d 129 (Vt. 1985). “The defendant, Dawn Bradley, was charged with driving a motor vehicle while under license suspension in violation of 23 V.S.A. § 674. The defendant pleaded guilty to the charge pursuant to a plea agreement made with the prosecutor.”
State v. Cady, 383 A.2d 607 (Vt. 1978). “23 V.S.A. § 674. [3] To sustain a violation of § 674, three elements must be proven: (1) suspension; (2) no reinstatement; and (3) operation.”
— Vt. Stat. Ann. tit. 23, § 674(a)(1) — 1 case
State v. Flagg, 624 A.2d 864 (Vt. 1993). “On August 22, 1991, defendant was charged with violating 23 V.S.A. § 674 as it existed at the time of defendant’s conduct.”
— Vt. Stat. Ann. tit. 23, § 674(a)(2) — 1 case
State v. Cram, 2008 VT 55 (Vt. 2008).
— Vt. Stat. Ann. tit. 23, § 674(b) — 9 cases
State v. Longe, 743 A.2d 569 (Vt. 1999). “In the instant case, § 674(b) establishes a maximum of two years imprisonment, a fine of $5,000, or both, if the underlying suspension was a result of a violation of § 1201.”
State v. Porter, 671 A.2d 1280 (Vt. 1996). “Lafountain involved a sentence enhancement for third-offense driving with license suspended, 23 V.S.A. § 674(b), in which the first offense is a civil violation carrying no prison sentence.”
In Re Miller, 2009 VT 36 (Vt. 2009). “§ 1210(d), carrying a maximum penalty of five years and/or a fine of $2,500; (2) one count of DLS-2, 23 V.S.A. § 674(b), carrying a maximum penalty of two years and/or a fine of $5,000; (3) one count of giving false information to a police officer, 13 V.”
State v. Millette, 795 A.2d 1182 (Vt. 2002). “A § 1711; (3) driving when his license had been suspended for DUI in Windsor County, in violation of 23 V.S.A. § 674(b); (4) driving when his license had been suspended for DUI from Bennington to Windham, in violation of 23 V.”
State v. LaFountain, 628 A.2d 1243 (Vt. 1993).
— Vt. Stat. Ann. tit. 23, § 674(c) — 5 cases
State v. Saari, 568 A.2d 344 (Vt. 1989). “See 23 V.S.A. § 674 (present subsection (a), rewritten in 1981, sets penalty for the first DLS offense at thirty days and/or $500); 13 V.”
State v. Bradley, 494 A.2d 129 (Vt. 1985). “The defendant, Dawn Bradley, was charged with driving a motor vehicle while under license suspension in violation of 23 V.S.A. § 674. The defendant pleaded guilty to the charge pursuant to a plea agreement made with the prosecutor.”
State v. Baker, 579 A.2d 479 (Vt. 1990). “Defendant appeals from a jury conviction of operating a motor vehicle while his license was suspended (DLS), in violation of 23 V.S.A. § 674(a). He alleges two errors: (1) the trial court placed the burden of proving the necessity defense upon him rather than requiring the State…”
State v. Potier, 547 A.2d 1359 (Vt. 1988).
State v. LeClair, 702 A.2d 628 (Vt. 1997).
— Vt. Stat. Ann. tit. 23, § 674(c)(1) — 2 cases
State v. Saari, 568 A.2d 344 (Vt. 1989). “See 23 V.S.A. § 674 (present subsection (a), rewritten in 1981, sets penalty for the first DLS offense at thirty days and/or $500); 13 V.”
State v. Baker, 579 A.2d 479 (Vt. 1990). “Defendant appeals from a jury conviction of operating a motor vehicle while his license was suspended (DLS), in violation of 23 V.S.A. § 674(a). He alleges two errors: (1) the trial court placed the burden of proving the necessity defense upon him rather than requiring the State…”
— Vt. Stat. Ann. tit. 23, § 674(f) — 1 case
State v. Longe, 743 A.2d 569 (Vt. 1999). “In the instant case, § 674(b) establishes a maximum of two years imprisonment, a fine of $5,000, or both, if the underlying suspension was a result of a violation of § 1201.”
— Vt. Stat. Ann. tit. 23, § 674(g) — 1 case
State v. Michael Witter (Vt. 2011).
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