Vermont Statutes Annotated

Vt. Stat. Ann. tit. 28, § 303 (2026)

✓ current as of May 2026
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Subchapter 003 : REVOCATION OF PROBATION

(Cite as: 28 V.S.A. § 303)
Notes of Decisions
Cited in 19 cases (3 in the last 5 years), 1985–2025 · leading case: State v. Lockwood, 632 A.2d 655 (Vt. 1993).
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State v. Lockwood, 632 A.2d 655 (Vt. 1993). · cites it 2× “2d 34, 36 (1989); see 28 V.S.A. § 303 (stating grounds for revocation).”
State v. Allen, 496 A.2d 168 (Vt. 1985). · cites it 2× “Appellant next claims that state law, 28 V.S.A. § 303(b), requires that a court make one of three findings before it may revoke probation: (1) Confinement is necessary to protect the community from further criminal activity by the probationer; or (2) The probationer is in need…”
State v. Peck, 547 A.2d 1329 (Vt. 1988). “28 V.S.A. § 303(b). Here, both concerns favor revocation.”
State v. Millard, 543 A.2d 700 (Vt. 1988). · cites it 2× “Finally, defendant contends that the district court did not make adequate findings as required by 28 V.S.A. § 303(b) in order to show the necessity for confinement.”
State v. Amidon, 2010 VT 46 (Vt. 2010). · cites it 2× “A. § 303(b)(2). ¶ 6. Defendant contends the State failed to provide sufficient evidence to prove that Bonnie had children under the age of eighteen, thereby failing to prove a *618 violation of the first probation condition precluding his participating in relationships with…”
State v. Cavett, 199 Vt. 546 (Vt. 2015). · cites it 2× “We based our decision primarily on 28 V.S.A. § 303(a), which authorizes revocation only if the probationer violates a condition of probation.”
State v. Cavett, 2015 VT 91 (Vt. 2015). · cites it 2× “We based our decision primarily on 28 V.S.A. § 303(a), which authorizes revocation only if the probationer violates a condition of probation.”
State v. Porter, 671 A.2d 1280 (Vt. 1996). “2d at 280 (quoting 28 V.S.A. § 303(b)). Unlike the statute at issue in DeRosa , a recidivism statute such as 23 V.”
State v. DeRosa, 633 A.2d 277 (Vt. 1993). “” 28 V.S.A. § 303(b) (emphasis added). It is not legally persuasive because the rationale of the right to counsel cases is to avoid the end result of incarcerating uncounseled defendants.”
State v. Gilbert, 2009 VT 7 (Vt. 2009). “On appeal, defendant argues that utterances without accompanying conduct do not constitute threatening behavior, that there was no evidence of any conduct component to defendant’s threats, and that the State therefore failed to allege a violation of probation condition M.”
State v. Bushey, 543 A.2d 1327 (Vt. 1988). “” 28 V.S.A. § 303(a). The trial court acts as the sole trier of fact, and its findings shall not be reversed unless defendant can show an abuse of discretion.”
State v. Amanda L. Stuart, 196 A.3d 306 (Vt. 2018). “28 V.S.A. § 303(b). The trial court in this case made no findings that indicate it conducted such an assessment.”
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— Vt. Stat. Ann. tit. 28, § 303(a) — 7 cases
State v. Cavett, 199 Vt. 546 (Vt. 2015). “We based our decision primarily on 28 V.S.A. § 303(a), which authorizes revocation only if the probationer violates a condition of probation.”
State v. Cavett, 2015 VT 91 (Vt. 2015). “We based our decision primarily on 28 V.S.A. § 303(a), which authorizes revocation only if the probationer violates a condition of probation.”
State v. Bushey, 543 A.2d 1327 (Vt. 1988). “” 28 V.S.A. § 303(a). The trial court acts as the sole trier of fact, and its findings shall not be reversed unless defendant can show an abuse of discretion.”
Christopher Sullivan v. Lisa Menard, Comm'r, 2019 VT 76 (Vt. 2019).
State v. Masse, 674 A.2d 1253 (Vt. 1995).
— Vt. Stat. Ann. tit. 28, § 303(b) — 10 cases
State v. Allen, 496 A.2d 168 (Vt. 1985). “Appellant next claims that state law, 28 V.S.A. § 303(b), requires that a court make one of three findings before it may revoke probation: (1) Confinement is necessary to protect the community from further criminal activity by the probationer; or (2) The probationer is in need…”
State v. Peck, 547 A.2d 1329 (Vt. 1988). “28 V.S.A. § 303(b). Here, both concerns favor revocation.”
State v. Millard, 543 A.2d 700 (Vt. 1988). “Finally, defendant contends that the district court did not make adequate findings as required by 28 V.S.A. § 303(b) in order to show the necessity for confinement.”
State v. Porter, 671 A.2d 1280 (Vt. 1996). “2d at 280 (quoting 28 V.S.A. § 303(b)). Unlike the statute at issue in DeRosa , a recidivism statute such as 23 V.”
State v. DeRosa, 633 A.2d 277 (Vt. 1993). “” 28 V.S.A. § 303(b) (emphasis added). It is not legally persuasive because the rationale of the right to counsel cases is to avoid the end result of incarcerating uncounseled defendants.”
— Vt. Stat. Ann. tit. 28, § 303(b)(2) — 1 case
State v. Amidon, 2010 VT 46 (Vt. 2010). “A. § 303(b)(2). ¶ 6. Defendant contends the State failed to provide sufficient evidence to prove that Bonnie had children under the age of eighteen, thereby failing to prove a *618 violation of the first probation condition precluding his participating in relationships with…”
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