Vermont Statutes Annotated

Vt. Stat. Ann. tit. 33, § 4913 (2026)

✓ current as of May 2026
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Subchapter 002 : REPORTING ABUSE OF CHILDREN

(Cite as: 33 V.S.A. § 4913)
Notes of Decisions
Cited in 19 cases (2 in the last 5 years), 1991–2025 · leading case: LaShay v. Dep't of Soc. & Rehab. Servs., 625 A.2d 224 (Vt. 1993).
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LaShay v. Dep't of Soc. & Rehab. Servs., 625 A.2d 224 (Vt. 1993). · cites it 5× “We also recognize private analogs to plaintiff’s claim under 33 V.S.A. § 4913, the child-abuse reporting statute.”
Lashay v. Dept. of Soc. & Rehab. Serv., 625 A.2d 224 (Vt. 1993). · cites it 5× “We also recognize private analogs to plaintiff's claim under 33 V.S.A. § 4913, the child-abuse reporting statute.”
Willis S. Sheldon, Individually & as Adm'r of the Est. of Dezirae Sheldon v. Nicholas Ruggiero, 202 A.3d 241 (Vt. 2018). · cites it 2× “On appeal, plaintiffs advocate three theories of liability based on: (1) an implied private right of action created by the mandated-reporter statute; (2) a common-law duty of care created and shaped by the mandated-reporter statute; and (3) the duty defendant assumed when he…”
In re G.T., 758 A.2d 301 (Vt. 2000). · cites it 2× “The majority first states that a plain-meaning construction of § 3252(a)(3) would be inconsistent with state statutory law requiring the reporting of child abuse, see 33 V.S.A. § 4913, which is defined to include rape, 33 V.”
State v. Rein Kolts, 205 A.3d 504 (Vt. 2018). “33 V.S.A. §§ 4913 -4914. Defendant's subjective belief that he needed to speak to the officers is irrelevant to a custody analysis.”
Miriam Lowell & Seth Healey v. Dep't for Child. & Families, 2024 VT 46 (Vt. 2024). “§ 4912(12), a redacted investigation file consists of “the intake report, the investigation activities summary, and case determination report that are amended in accordance with confidentiality requirements set forth in [33 V.S.A. § 4913]. By statute, some of this information is…”
Wilkinson v. Balsam, 885 F. Supp. 651 (D. Vt. 1995). · cites it 2× “33 V.S.A. § 4913(a) provides: Any physician .”
State v. Barron, 2011 VT 2 (Vt. 2011). “See 33 V.S.A. § 4913(a) (requiring police officer who has reasonable cause to believe that any child 2 has been abused to report to Commissioner within twenty-four hours).”
F.E.F. v. Cameron, 594 A.2d 897 (Vt. 1991). “See 33 V.S.A. § 4913(a). The nature of SRS action in confirmed cases of child abuse and neglect varies.”
Hermanson v. State, 604 So. 2d 775 (Fla. 1992). “5 (1992); Vermont: Vt. Stat. Ann. tit. 33, § 4913 (C) (1991); Virginia: Va.”
Tucker v. Decker, 683 F. App'x 20 (2d Cir. 2017). “” Vt. Stat. Ann. tit. 33, § 4913 (a) (2013).”
State v. Duffy, 605 A.2d 533 (Vt. 1992). “Due to the short time frame of the statutory reporting requirements, see 33 V.S.A. §§ 4913(a) and 4915(a), SRS investigators are often among the first persons to talk directly to children who may have been abused.”
Show all 19 citing cases →
— Vt. Stat. Ann. tit. 33, § 4913(1) — 2 cases
Wilkinson ex rel. Wilkinson v. Russell, 973 F. Supp. 437 (D. Vt. 1997).
Wilkinson by & Through Wilkinson v. Russell, 973 F. Supp. 437 (D. Vt. 1997).
— Vt. Stat. Ann. tit. 33, § 4913(a) — 11 cases
LaShay v. Dep't of Soc. & Rehab. Servs., 625 A.2d 224 (Vt. 1993). “We also recognize private analogs to plaintiff’s claim under 33 V.S.A. § 4913, the child-abuse reporting statute.”
Lashay v. Dept. of Soc. & Rehab. Serv., 625 A.2d 224 (Vt. 1993). “We also recognize private analogs to plaintiff's claim under 33 V.S.A. § 4913, the child-abuse reporting statute.”
In re G.T., 758 A.2d 301 (Vt. 2000). “The majority first states that a plain-meaning construction of § 3252(a)(3) would be inconsistent with state statutory law requiring the reporting of child abuse, see 33 V.S.A. § 4913, which is defined to include rape, 33 V.”
State v. Barron, 2011 VT 2 (Vt. 2011). “See 33 V.S.A. § 4913(a) (requiring police officer who has reasonable cause to believe that any child 2 has been abused to report to Commissioner within twenty-four hours).”
F.E.F. v. Cameron, 594 A.2d 897 (Vt. 1991). “See 33 V.S.A. § 4913(a). The nature of SRS action in confirmed cases of child abuse and neglect varies.”
— Vt. Stat. Ann. tit. 33, § 4913(c) — 1 case
Wilkinson v. Balsam, 885 F. Supp. 651 (D. Vt. 1995). “33 V.S.A. § 4913(a) provides: Any physician .”
— Vt. Stat. Ann. tit. 33, § 4913(f)(1) — 1 case
Av v. Dcf (Vt. Super. Ct. 2025).
— Vt. Stat. Ann. tit. 33, § 4913(i) — 1 case
Av v. Dcf (Vt. Super. Ct. 2025).
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