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Welcome to the Vermont Model Criminal Jury Instructions. The instructions are sponsored by the Vermont Bar Association.
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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
Aggravated Assault (threatened another with deadly weapon)
December 31, 2020: The Committee has updated the instruction for aggravated assault (threatened another with deadly weapon), CR22-098. That instruction is available here.
Violation of Abuse Prevention Order (VAPO)
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.
Dismissal During Trial of Some Charges Against Single Defendant
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.”
Permissive Inference of Drug Possession
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.
Voluntariness of Confession; Invited Error Doctrine
October 8, 2020: The Committee has added a reference to State v. Kolts, 2018 VT 131, ¶¶ 39–41 to the reporter’s note for CR05-351 (Defendant’s Out-of-Court Statements), and a reference to State v. Morse, 2019 VT 58, ¶¶ 6–7 (discussing … Continue reading
Disclosure of Sexually Explicit Images Without Consent
October 2, 2020: The Committee has revised the instruction and reporter’s note for the crime of “Disclosure of Sexually Explicit Images Without Consent” (CR27-611) to reflect the Vermont Supreme Court’s decision in State v. Van Buren, 2018 VT 95, ¶¶ … Continue reading
Multiple Defendants
September 18, 2020: The Committee has added a new instruction (CR04-051) and reporter’s note for use in cases with more than one defendant on trial.
Reckless Endangerment
September 18, 2020: The Committee has revised the instructions and reporter’s note for Reckless Endangerment (CR22-121, -126) to be consistent with the recent revision to the general definition of recklessness (CR06-141).
Eluding a Police Officer
September 8, 2020: The Committee has updated the instructions and reporter’s note for the crime of eluding a police officer.
Recklessness
August 28, 2020: The Committee has revised the instruction for the mental state “recklessly,” CR06-141, and the accompanying reporter’s note. The revised instruction and note can be found on the Mental Elements page.