Vt. Stat. Ann. » Title 23 Chapter 11
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 23, § 800 (2026)

✓ current as of May 2026
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Subchapter 001 : GENERAL PROVISIONS

(Cite as: 23 V.S.A. § 800)
Notes of Decisions
Cited in 17 cases (2 in the last 5 years), 1991–2021 · leading case: Colwell v. Allstate Ins., 2003 VT 5 (Vt. 2003).
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Colwell v. Allstate Ins., 2003 VT 5 (Vt. 2003). · cites it 4× “§ 809 (waiver of proof of financial responsibility “shall not be construed to relieve an operator of his or her responsibility to comply with the mandatory insurance requirement set forth in 23 V.S.A. § 800”). The statute prescribes either an insurance policy, surety bond, or…”
Peter I. Diamondstone v. Christopher A. MacAluso Leroy Prior, David R. Stanton, A. James Walton, Jr., & State of Vermont, 148 F.3d 113 (2d Cir. 1998). · cites it 4× “The officer cited Diamondstone for driving without insurance in violation of Vt. Stat. Ann. tit. 23, § 800 . A Vermont district court ruled that Diamond-stone had a constitutional right to refuse to say whether or not he had auto insurance and that his refusal to answer a police…”
Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009). · cites it 4× “See 23 V.S.A. § 800(a) (setting forth the requirement that drivers maintain "an automobile liability policy" with minimum liability coverage); id.”
Davis v. Liberty Mut. Ins. Co., 19 F. Supp. 2d 193 (D. Vt. 1998). · cites it 9× “Does the fellow employee exclusion clause violate section 800(a) of title 23 of Vermont Statutes Annotated, Vermont’s financial responsibility statute? See Vt. Stat. Ann. tit. 23, § 800 (a) (1987 & Supp.”
State v. Stephanie Berard, 2019 VT 65 (Vt. 2019). “And 23 V.S.A. § 800(c) requires that a driver must also provide proof of valid car insurance.”
Progressive Ins. v. Brown Ex Rel. Brown, 2008 VT 103 (Vt. 2008). “In fact, in Monteith , we specifically rejected the insurer’s claim that 23 V.S.A. § 800(a), which requires operators to obtain insurance for their vehicles, limits UM coverage to vehicles insured under an individual’s policy.”
Am. Cas. Co. of Reading, Pennsylvania v. Nordic Leasing, Inc., 42 F.3d 725 (2d Cir. 1994). “23 V.S.A. § 800. In addition, it requires individuals who have been convicted of drunk driving and various other offenses, as John Morin was (“convicted drivers”), to file proof of financial responsibility in the amount specified by statute, in the form of a bond or insurance…”
Smith v. Nationwide Mut. Ins., 2003 VT 61 (Vt. 2003). “This approach is entirely consistent with an insurer’s duty to defend its insured and the overriding purpose for mandatory automobile liability insurance.”
State Farm Mut. Auto. Co. v. Colby & Lamotte, 2013 VT 80 (Vt. 2013). “§ 941 (detailing uninsured, underinsured, and hit-and-run insurance protections for purpose of providing victim compensation).”
Coop. Fire Ins. v. Gray, 599 A.2d 360 (Vt. 1991). “” 23 V.S.A. § 800(a). The Legislature has provided that: (b) Every policy insuring against liability arising out of the ownership, maintenance or use of any motor vehicle shall provide insurance against loss resulting from the liability imposed by law for damages because of…”
Champlain Cas. Co. v. Agency Rent-A-Car, Inc., 716 A.2d 810 (Vt. 1998). “See 23 V.S.A. § 800(a). In lieu thereof, the owner may file self-insurance in the amount of $100,000.”
Co-op Fire Ins. Ass'n of Vermont v. Gray, 599 A.2d 360 (Vt. 1991). “" 23 V.S.A. § 800(a). The Legislature has provided that: (b) Every policy insuring against liability arising out of the ownership, maintenance or use of any motor vehicle shall provide insurance against loss resulting from the liability imposed by law for damages because of…”
Show all 17 citing cases →
— Vt. Stat. Ann. tit. 23, § 800(a) — 8 cases
Colwell v. Allstate Ins., 2003 VT 5 (Vt. 2003). “§ 809 (waiver of proof of financial responsibility “shall not be construed to relieve an operator of his or her responsibility to comply with the mandatory insurance requirement set forth in 23 V.S.A. § 800”). The statute prescribes either an insurance policy, surety bond, or…”
Ins. Co. of State of Pa. v. Johnson, 2009 VT 92 (Vt. 2009). “See 23 V.S.A. § 800(a) (setting forth the requirement that drivers maintain "an automobile liability policy" with minimum liability coverage); id.”
Progressive Ins. v. Brown Ex Rel. Brown, 2008 VT 103 (Vt. 2008). “In fact, in Monteith , we specifically rejected the insurer’s claim that 23 V.S.A. § 800(a), which requires operators to obtain insurance for their vehicles, limits UM coverage to vehicles insured under an individual’s policy.”
Smith v. Nationwide Mut. Ins., 2003 VT 61 (Vt. 2003). “This approach is entirely consistent with an insurer’s duty to defend its insured and the overriding purpose for mandatory automobile liability insurance.”
Coop. Fire Ins. v. Gray, 599 A.2d 360 (Vt. 1991). “” 23 V.S.A. § 800(a). The Legislature has provided that: (b) Every policy insuring against liability arising out of the ownership, maintenance or use of any motor vehicle shall provide insurance against loss resulting from the liability imposed by law for damages because of…”
— Vt. Stat. Ann. tit. 23, § 800(c) — 1 case
State v. Stephanie Berard, 2019 VT 65 (Vt. 2019). “And 23 V.S.A. § 800(c) requires that a driver must also provide proof of valid car insurance.”
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