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.
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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.
Author Archives: Michael Csere
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 … Continue reading
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 … Continue reading
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.
December 18, 2020: The Committee recently revised the instruction and reporter’s note for VAPO to reflect a recent statutory amendment that explicitly adds an element of general intent.
October 12, 2020: The Committee added a new reporter’s note to accompany model instruction CR03-061, and also changed the caption for that instruction from “Partial Rule 29 Dismissal” to “Dismissal During Trial of Some Charges Against Single Defendant.”
October 12, 2020: The Committee has added a new instruction: CR40-801, Permissive Inference of Drug Possession (presence in automobile), based on 18 V.S.A. § 4221(b). The accompanying reporter’s note is available here.