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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.
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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
Unlawful Mischief
August 26, 2025: The Committee has revised the reporter’s note for unlawful mischief to incorporate references to State v. Lyddy, 2025 VT 1 and State v. Wells, 2025 VT 5.
Illegal Taking of Game
August 1, 2025: The Committee has revised the model instructions for illegally taking a deer and shooting at a wild animal from a public highway to more accurately track the statutory language.
Carrying a Weapon While Committing a Felony
August 1, 2025: The Committee has added a new model instruction and reporter’s note for the crime of Carrying a Weapon While Committing a Felony, 13 V.S.A. § 4005.
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.