Vt. Stat. Ann. » Title 28 Chapter 5
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 28, § 252 (2026)

✓ current as of May 2026
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Subchapter 002 : CONDITIONS OF PROBATION; MODIFICATIONS; DISCHARGE

(Cite as: 28 V.S.A. § 252)
Notes of Decisions
Cited in 70 cases (9 in the last 5 years), 1970–2025 · leading case: State v. Billy Joe Putnam, 2015 VT 113 (Vt. 2015).
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State v. Billy Joe Putnam, 2015 VT 113 (Vt. 2015). · cites it 28× “Instead, they are a tool to put before the sentencing judge a range of potential conditions for consideration if justified by the circumstances of the case.”
State v. Hemingway, 2014 VT 48 (Vt. 2014). · cites it 15× “Thus, the requirement that defendant be provided with a “certificate explicitly setting forth the conditions upon which he or she is being released,” 28 V.S.A. § 252, is not satisfied by the plea agreement, because the conditions of release are ultimately still set by the court…”
State v. Moses, 618 A.2d 478 (Vt. 1992). · cites it 8× “28 V.S.A. §§ 252(a) (condition must be "reasonably necessary to ensure that the offender will lead a law-abiding life or to assist [her] to do so"), 252(b)(13) (conditions permitted if "reasonably related to .”
State v. Bostwick, 2014 VT 97 (Vt. 2014). · cites it 8× “Further, we have couched this principle of specificity in the trial court’s statutory authority to impose conditions under 28 V.S.A. § 252, and the consequent impermissibility of delegation of this authority to probation officers.”
State v. Jarvis, 509 A.2d 1005 (Vt. 1986). · cites it 7× “§ 252(b)(6), the court may require, as a condition of probation, that the offender “[m]ake restitution or reparation to the victim of his conduct for the damage or injury which was sustained.”
State v. Nelson, 742 A.2d 1248 (Vt. 1999). · cites it 8× “A trial court's decision, in particular, to suspend a criminal sentence and impose conditions of probation under 28 V.S.A. § 252 represents an essential tool in the court's ability to shape a criminal sentence to the rehabilitative needs of the individual defendant.”
State v. Thomas Gauthier, 2016 VT 37 (Vt. 2016). · cites it 4× “According to defendant the “special sex-offender conditions” listed on the “State’s 1” attachment are unenforceable because the probation order did not provide him adequate notice that he was subject to each and every one of the conditions listed, but not checked, on that…”
State v. Willy Levitt, 2016 VT 60 (Vt. 2016). · cites it 3× “Defendant notes that 28 V.S.A. § 252(a) requires only one condition in a simple assault case — permitting revocation of probation if the defendant is convicted of another offense during the probationary period, represented here in condition B.”
State v. Owen Cornell, 2016 VT 47 (Vt. 2016). · cites it 3× “A sentencing court has authority to establish probation conditions that are reasonably related to the crime committed and have been deemed necessary to “ensure that the offender will lead a law-abiding life.”
State v. James Anderson, 2016 VT 40 (Vt. 2016). · cites it 5× “2d 996, 998 (1979) (citing 28 V.S.A. § 252; ABA Standards, *9 Probation § 1.”
State v. Peck, 547 A.2d 1329 (Vt. 1988). · cites it 3× “” 28 V.S.A. § 252(a); see also Bubar, 146 Vt.”
State v. Bohannon, 2010 VT 22 (Vt. 2010). · cites it 4× “Moreover, as it was enacted in conjunction with 28 V.S.A. § 252 as part of the "Crime Victim's Bill of Rights," the two statutes "are parts of a statutory scheme dealing with restitution, and they should be construed together.”
Show all 70 citing cases →
— Vt. Stat. Ann. tit. 28, § 252(a) — 28 cases
State v. Billy Joe Putnam, 2015 VT 113 (Vt. 2015). “Instead, they are a tool to put before the sentencing judge a range of potential conditions for consideration if justified by the circumstances of the case.”
State v. Willy Levitt, 2016 VT 60 (Vt. 2016). “Defendant notes that 28 V.S.A. § 252(a) requires only one condition in a simple assault case — permitting revocation of probation if the defendant is convicted of another offense during the probationary period, represented here in condition B.”
State v. Yetha L. Lumumba, 187 A.3d 353 (Vt. 2018).
State v. Nelson, 742 A.2d 1248 (Vt. 1999). “A trial court's decision, in particular, to suspend a criminal sentence and impose conditions of probation under 28 V.S.A. § 252 represents an essential tool in the court's ability to shape a criminal sentence to the rehabilitative needs of the individual defendant.”
State v. Lockwood, 632 A.2d 655 (Vt. 1993).
— Vt. Stat. Ann. tit. 28, § 252(b) — 12 cases
State v. Billy Joe Putnam, 2015 VT 113 (Vt. 2015). “Instead, they are a tool to put before the sentencing judge a range of potential conditions for consideration if justified by the circumstances of the case.”
State v. Moses, 618 A.2d 478 (Vt. 1992). “28 V.S.A. §§ 252(a) (condition must be "reasonably necessary to ensure that the offender will lead a law-abiding life or to assist [her] to do so"), 252(b)(13) (conditions permitted if "reasonably related to .”
State v. Bubar, 505 A.2d 1197 (Vt. 1985).
MacE v. Amestoy, 765 F. Supp. 847 (D. Vt. 1991).
State v. Campbell, 120 A.3d 1148 (Vt. 2015).
— Vt. Stat. Ann. tit. 28, § 252(b)(1) — 1 case
State v. Billy Joe Putnam, 2015 VT 113 (Vt. 2015). “Instead, they are a tool to put before the sentencing judge a range of potential conditions for consideration if justified by the circumstances of the case.”
— Vt. Stat. Ann. tit. 28, § 252(b)(10) — 1 case
State v. Kelly Burket (Vt. 2025).
— Vt. Stat. Ann. tit. 28, § 252(b)(13) — 3 cases
State v. Moses, 618 A.2d 478 (Vt. 1992). “28 V.S.A. §§ 252(a) (condition must be "reasonably necessary to ensure that the offender will lead a law-abiding life or to assist [her] to do so"), 252(b)(13) (conditions permitted if "reasonably related to .”
State v. Peck, 547 A.2d 1329 (Vt. 1988). “” 28 V.S.A. § 252(a); see also Bubar, 146 Vt.”
State v. Gleason, 576 A.2d 1246 (Vt. 1990).
— Vt. Stat. Ann. tit. 28, § 252(b)(15) — 1 case
State v. Lewis, 711 A.2d 669 (Vt. 1998).
— Vt. Stat. Ann. tit. 28, § 252(b)(16) — 1 case
State v. Campbell, 120 A.3d 1148 (Vt. 2015).
— Vt. Stat. Ann. tit. 28, § 252(b)(18) — 11 cases
State v. Bostwick, 2014 VT 97 (Vt. 2014). “Further, we have couched this principle of specificity in the trial court’s statutory authority to impose conditions under 28 V.S.A. § 252, and the consequent impermissibility of delegation of this authority to probation officers.”
State v. Landon T. Urban, 184 A.3d 731 (Vt. 2018).
State v. Owen Cornell, 2016 VT 47 (Vt. 2016). “A sentencing court has authority to establish probation conditions that are reasonably related to the crime committed and have been deemed necessary to “ensure that the offender will lead a law-abiding life.”
State v. Sanville, 2011 VT 34 (Vt. 2011).
State v. James Careau, 2016 VT 18 (Vt. 2016).
— Vt. Stat. Ann. tit. 28, § 252(b)(2) — 1 case
State v. Billy Joe Putnam, 2015 VT 113 (Vt. 2015). “Instead, they are a tool to put before the sentencing judge a range of potential conditions for consideration if justified by the circumstances of the case.”
— Vt. Stat. Ann. tit. 28, § 252(b)(6) — 15 cases
State v. Jarvis, 509 A.2d 1005 (Vt. 1986). “§ 252(b)(6), the court may require, as a condition of probation, that the offender “[m]ake restitution or reparation to the victim of his conduct for the damage or injury which was sustained.”
State v. Lucas Dwight, 194 A.3d 1163 (Vt. 2018).
State v. Bohannon, 2010 VT 22 (Vt. 2010). “Moreover, as it was enacted in conjunction with 28 V.S.A. § 252 as part of the "Crime Victim's Bill of Rights," the two statutes "are parts of a statutory scheme dealing with restitution, and they should be construed together.”
In Re Fadden, 530 A.2d 560 (Vt. 1987).
State v. Randell Blake, 174 A.3d 126 (Vt. 2017).
— Vt. Stat. Ann. tit. 28, § 252(b)(7) — 1 case
State v. Lewis, 711 A.2d 669 (Vt. 1998).
— Vt. Stat. Ann. tit. 28, § 252(b)(9) — 1 case
State v. Billy Joe Putnam, 2015 VT 113 (Vt. 2015). “Instead, they are a tool to put before the sentencing judge a range of potential conditions for consideration if justified by the circumstances of the case.”
— Vt. Stat. Ann. tit. 28, § 252(c) — 10 cases
State v. Hemingway, 2014 VT 48 (Vt. 2014). “Thus, the requirement that defendant be provided with a “certificate explicitly setting forth the conditions upon which he or she is being released,” 28 V.S.A. § 252, is not satisfied by the plea agreement, because the conditions of release are ultimately still set by the court…”
State v. Thomas Gauthier, 2016 VT 37 (Vt. 2016). “According to defendant the “special sex-offender conditions” listed on the “State’s 1” attachment are unenforceable because the probation order did not provide him adequate notice that he was subject to each and every one of the conditions listed, but not checked, on that…”
State v. James Anderson, 2016 VT 40 (Vt. 2016). “2d 996, 998 (1979) (citing 28 V.S.A. § 252; ABA Standards, *9 Probation § 1.”
State v. Owen Cornell, 2016 VT 47 (Vt. 2016). “A sentencing court has authority to establish probation conditions that are reasonably related to the crime committed and have been deemed necessary to “ensure that the offender will lead a law-abiding life.”
State v. Patricia Kane, 169 A.3d 762 (Vt. 2017).
— Vt. Stat. Ann. tit. 28, § 252(e) — 1 case
State v. Katon, 719 A.2d 430 (Vt. 1998).
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