Welcome to the Vermont Model Criminal Jury Instructions. The instructions are sponsored by the Vermont Bar Association.
Use the drop-down menus above or the search function below to find individual instructions and the accompanying reporter's notes.
In addition, clicking on the menu headers above will show a table of contents for that section, and there is also a master table of contents available. Long-time users of the instructions will find the master table of contents to be in the familiar format.
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You may search for an instruction by using the name of the crime (e.g., kidnapping) or by using the statutory citation (e.g., 13 V.S.A. 2405 or, more simply, 2405). Note that the search software is simply reading the text on each page, and thus doesn't recognize "VSA" without the periods.
February 9, 2022: The Committee has revised several reporter’s notes on the “Burden of Proof” page to incorporate references to State v. Redmond, 2020 VT 36, 212 Vt. 242 and State v. Blanchard, 2021 VT 13, ¶ 34.
February 9, 2022: The Committee has added a new instruction and reporter’s note for pro se defendants.
March 5, 2021: The Committee has revamped and expanded the reporter’s note for the hung jury (“Allen” ) charge. The expanded note incorporates discussion from State v. Rolls, 2020 VT 18, ¶¶ 13–20.
March 5, 2021: The Committee has revised the reporter’s note accompanying the transition instructions, which appear on multiple pages on this website, to add a reference to State v. Rolls, 2020 VT 18, ¶ 9 (trial court did not err in providing both hard and soft transition instructions, rather than one or the other, in the absence of defendant’s request). See, for example, the reporter’s note on the homicide page.
March 4, 2021: The Committee has added a reference to State v. Kandzior, 2020 VT 37, ¶ 27 (“the failure to investigate possible jury taint and establish an evidentiary basis for determining if the jury was fair and unbiased amounts to plain error”) to the reporter’s notes accompanying the juror prohibition instructions, available here and here.
January 11, 2021: The Committee has added a new model instruction and reporter’s note for the crime of criminal threatening, 13 V.S.A. § 1702, available here.
January 8, 2021: The Committee has revised the instruction and reporter’s note for evidence of flight, CR05-501.
January 8, 2021: The Committee has created new instructions and a reporter’s note for the crime of sexual exploitation of a minor, 13 V.S.A. § 3258. The new instructions include both misdemeanor and felony versions.
December 31, 2020: The Committee has updated the instruction for aggravated assault (threatened another with deadly weapon), CR22-098. That instruction is available here.