Vermont Statutes Annotated

Vt. Stat. Ann. tit. 28, § 851 (2026)

✓ current as of May 2026
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Subchapter 004 : DISCIPLINE AND CONTROL OF INMATES

(Cite as: 28 V.S.A. § 851)
Notes of Decisions
Cited in 5 cases (3 in the last 5 years), 1993–2024 · leading case: Zachary Rose v. Michael Touchette, Comm'r, Dep't of Corr., 2021 VT 77 (Vt. 2021).
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Zachary Rose v. Michael Touchette, Comm'r, Dep't of Corr., 2021 VT 77 (Vt. 2021). · cites it 5× “He argues that his program termination constituted punishment under 28 V.S.A. § 851 and therefore required a hearing and due process under § 852.”
Conway v. Cumming, 636 A.2d 735 (Vt. 1993). · cites it 2× “§ 1983 for violation under color of state law of federally protected civil rights, including rights guaranteed under the Eighth Amendment (guarantee against cruel and unusual punishment) and Fourteenth Amendment (due process of law); for violation of Chapter I, Article 4 of the…”
Borden v. Hofmann, 2009 VT 30 (Vt. 2009). · cites it 2× “This case requires us to determine whether placing an inmate on a Nutraloaf-and-water diet in response to misconduct constitutes "punishment" within the meaning of 28 V.S.A. § 851, thereby requiring a hearing prior to implementation of the diet *1250 under § 852.”
McLaughlin v. Baker (Vt. Super. Ct. 2024). “McLaughlin argues that the relevant statutes, 28 V.S.A. §§ 851–853, clearly require a hearing prior to the imposition of any punishment whatsoever, without distinguishing among the types of violations or severity of punishment.”
Ferraro v. Baker (Vt. Super. Ct. 2021). “Analysis The disciplinary process is governed by 28 V.S.A. § 851. It is supplemented by DOC Directive 410.”
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