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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
Forgery
September 21, 2026: The Committee has added new instructions and a reporter’s note for the crime of forgery.
Unlawful Trespass (locked building)
July 12, 2026: The Committee has revised the instruction for unlawful trespass (locked building) to track the current statutory language. The Committee has also added a new reporter’s note for that instruction. The revised instruction and new reporter’s note are … Continue reading
Unlawful Trespass (motor vehicle)
March 9, 2026: The Committee has added a new instruction for unlawful trespass (motor vehicle), 13 V.S.A. § 3705(c), available here.
DUI (Under Influence of Drugs or Combination)
February 13, 2026: The Committee has revised the instructions for DUI (under influence of drugs or combination) to conform with the statutory language.
Insanity
February 13, 2026: The Committee updated the reporter’s note for the insanity defense to include a citation to State v. Gurung, 2025 VT 52, ¶¶ 46–62.
Defendant Not Testifying at Trial
February 13, 2026: The Committee has explained in the reporter’s note for the “Defendant Not Testifying at Trial” instruction that it has declined a specific request to revise that instruction at this time, pending further guidance from the Supreme Court … Continue reading
Sexual Assault
November 19, 2025: The Committee has updated the sexual assault reporter’s note to add references to State v. Orost, 2025 VT 15, ¶¶ 39–44, 48.
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.