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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.
Author Archives: Michael Csere
First Degree Aggravated Domestic Assault (deadly weapon variations)
April 8, 2025. The Committee has revised and renumbered the model instructions for First Degree Aggravated Domestic Assault (used deadly weapon and threatened to use deadly weapon), and added a new instruction for attempt to use a deadly weapon. Those … Continue reading
Drug Crime Revisions; New Model Instructions for Fentanyl, Xylazine, Selling a Regulated Drug with Death Resulting
April 1, 2025: The Committee has made numerous changes to the drug crime model instructions. These changes incorporate new statutory language and reference State v. Rillo, 2020 VT 82, ¶ 12, 213 Vt. 193. Additionally, the Committee has added new … Continue reading
Driving with License Suspended (DLS)
January 9, 2025: The Committee has revised the preexisting DLS instruction, added a new instruction for 23 V.S.A. § 674(b), and revised the reporter’s note. The revisions better track the statutory language. The DLS instructions and reporter’s notes are available … Continue reading
Lewd or Lascivious Conduct with Child
January 9, 2025: The Committee has updated the reporter’s note for Lewd or Lascivious Conduct with Child, adding a citation to State v. Grant, 2024 WL 167139, at *3–5 (Vt. Jan. 12, 2024) (unpub. mem.).
State v. Phillips: Unanimity and Special Verdict Forms
July 12, 2024: The Committee has added a citation to State v. Phillips, 2024 VT 10, ¶ 16 in the reporter’s notes here, here, and here.
Diminished Capacity and Intoxication
July 8, 2024: The Committee has added a citation to State v. Taylor, 2023 VT 60, ¶¶ 9–19 to the reporter’s note for diminished capacity and intoxication.
Insanity
June 10, 2024: The Committee has revised the instruction and reporter’s note for the insanity defense to better track the statutory language.
Domestic Terrorism
June 10, 2024: The Committee has added a new instruction and reporter’s note for the crime of domestic terrorism, 13 V.S.A. § 3521, available here.
Old Versions of Model Instructions
February 12, 2024: Please note that the Committee maintains an archive of old, outdated model instructions, but that this archive is not available on the website. If you need an old version of a model instruction, please email the Committee … Continue reading
Hate Crimes
December 6, 2023: The Committee has revised the hate crime model instruction to reflect a 2021 statutory amendment. See 2021, No. 34, § 1 (eff. May 18, 2021).