State v. Jay H. Orost

2025 VT 15
CourtSupreme Court of Vermont
DecidedMarch 28, 2025
Docket23-AP-345
StatusPublished
Cited by3 cases

This text of 2025 VT 15 (State v. Jay H. Orost) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Jay H. Orost, 2025 VT 15 (Vt. 2025).

Opinion

NOTICE: This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports. Readers are requested to notify the Reporter of Decisions by email at: Reporter@vtcourts.gov or by mail at: Vermont Supreme Court, 109 State Street, Montpelier, Vermont 05609-0801, of any errors in order that corrections may be made before this opinion goes to press.

2025 VT 15

No. 23-AP-345

State of Vermont Supreme Court

On Appeal from v. Superior Court, Lamoille Unit, Criminal Division

Jay H. Orost December Term, 2024

Michael J. Harris, J.

Evan Meenan, Deputy States’s Attorney, Montpelier, for Plaintiff-Appellee.

Matthew Valerio, Defender General, and Dawn Matthews, Appellate Defender, Montpelier, for Defendant-Appellant.

PRESENT: Reiber, C.J., Eaton, Carroll and Cohen, JJ., and Toor, Supr. J. (Ret.), Specially Assigned

¶ 1. EATON, J. Defendant Jay Orost appeals jury convictions for sexual assault,

lewd and lascivious conduct, and obstruction of justice. He argues that his convictions should be

reversed because of jury irregularities, errors in evidentiary rulings, and misleading jury

instructions. We affirm.

I. Facts

¶ 2. In September 2017, K.O., then seventeen, told her guidance counselor that her

father, defendant Jay Orost had sexually assaulted her for the last seven years; starting when she

was ten years old to as recently as the morning she reported the abuse. Following an

investigation into the events, the State charged defendant with twelve counts including two counts of sexual assault of K.O., two counts of aggravated repeated sexual assault of K.O, a

count of aggravated domestic assault of K.O., and multiple counts of lewd and lascivious

conduct perpetrated against K.O. and another minor, A.S. The State also charged defendant with

obstruction of justice based on defendant’s actions during the investigation. In January 2022, a

jury found defendant guilty of all counts except aggravated domestic assault of K.O, and,

instead, found him guilty of domestic assault, a lesser-included offense.

¶ 3. Defendant appeals his convictions and asks that this Court reverse and remand for

a new trial. He argues that his Sixth Amendment right to an impartial jury was violated, that

evidentiary rulings undermined his right to a fair trial, and that the jury instructions were flawed.

As explained more fully below, we conclude that there was no error and affirm.1

II. Right to an Impartial Jury

¶ 4. To understand the relevant issues raised by defendant concerning potential jury

bias due to the jury-selection process, an explanation of defendant’s relationship to his current

wife and to K.O., one of the complainants, is necessary. In 1985, defendant married Lori Tinker

(Pindell) and adopted her daughters, Katie and Kari. In 2000, defendant’s adopted daughter,

1 During the pendency of this appeal, defendant was represented by counsel from the Office of the Defender General. Notwithstanding his representation, defendant personally submitted numerous letters and motions with the Court alleging errors in the trial court proceedings and on appeal including alleged inadequacies with his representation by his assigned appellate counsel. As this Court previously ruled, defendant did not present good cause to replace his assigned counsel, who filed an appellate brief raising numerous issues and presented oral argument on defendant’s behalf. To the extent defendant raised ineffective-assistance claims, they may not be presented in a direct appeal. See State v. Lund, 168 Vt. 102, 105, 718 A.2d 413, 415 (1998) (explaining that claim for ineffective assistance of counsel “must be raised, if at all, in the context of a petition for post-conviction relief”). Furthermore, because defendant was represented by counsel, we do not address the issues raised in the filings submitted without counsel. Although defendant is entitled to effective legal counsel, defendant “does not have an absolute right to both self-representation and the assistance of counsel.” State v. Sims, 158 Vt. 173, 185, 608 A.2d 1149, 1156 (1991) (emphasis omitted) (quoting United States v. Halbert, 640 F.2d 1000, 1009 (9th Cir. 1981)). Moreover, when a litigant is represented by counsel, counsel must sign pleadings, and the filing sent to this Court by defendant did not include his attorney’s signature. See V.R.A.P. 25(d)(1) (requiring counsel to sign document if party is represented by counsel). 2 Katie, gave birth to defendant’s child, K.O., who is one of the complainants in this case. In

2004, defendant divorced Lori and married Katie. During the jury draw, defense counsel

articulated his concern that a juror might “know[] the family dynamics” and “the whole story”

and, consequently, be biased against defendant. On appeal, defendant argues that he was not

afforded his constitutional right to an impartial jury because the trial court incorrectly concluded

that two potential jurors were unbiased—despite indications that they might know or might be

reminded of defendant’s family and family history—and because the court declined defendant’s

request to make a particular juror (who had worked with a complaining witness) an alternate

rather than a member of the final jury.

¶ 5. We begin with a description of the relevant events during the jury draw. When

questioned, prospective juror Tilton indicated that he was “possibly [aware of defendant’s] sister,

Janice.” Defense counsel later clarified to the court that, based on Mr. Tilton’s answers and

description of the woman, Mr. Tilton was likely indicating that he was aware of defendant’s ex-

wife, Lori—mother of his current wife—not defendant’s sister. When asked directly about

defendant’s ex-wife, however, Mr. Tilton indicated some uncertainty: “Lori? I am trying to

remember her name. Her maiden name, right?” But when asked whether he knew her

connection to defendant, Mr. Tilton replied: “No. No.” When asked if there was anything

“which would impact your ability to be a fair juror,” Mr. Tilton responded, “I don’t believe so.”

Defense counsel subsequently requested a for-cause challenge against Mr. Tilton. The court

declined to exclude the juror for cause, reasoning “I don’t see where that potential juror has

enough recollection of . . . anything of the family. This is twenty years ago, and he hasn’t had

ongoing knowledge. He couldn’t remember the relationship or anything.” Defense counsel then

used a peremptory challenge for Mr. Tilton, stating “we feel we have no choice.”

¶ 6. Prospective juror Billado worked at Global Foundries, defendant’s former

employer. During questioning, Mr. Billado indicated: defendant’s name “[rang] a bell,” he

3 remembered reading something about the case in the past, he assumed that his coworkers knew

defendant, and he stated “my wife knows what the case is. And she said she knows [defendant]

from . . . childhood, neighborhood-type stuff.” However, even though his wife had discussed the

case with him, Mr. Billado summarized his knowledge of the case, stating he had only “a foggy

recollection of something going on in the past . . . I couldn’t write a story and tell you what went

on.” When asked if he had any concerns that some of the evidence might trigger his memory of

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