State v. Kent Eaton

CourtSupreme Court of Vermont
DecidedMay 1, 2026
Docket24-AP-121
StatusPublished

This text of State v. Kent Eaton (State v. Kent Eaton) 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. Kent Eaton, (Vt. 2026).

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.

2026 VT 14

No. 24-AP-121

State of Vermont Supreme Court

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

Kent Eaton September Term, 2025

Michael S. Kupersmith, J. (Ret.) (motion to suppress); John L. Pacht, J. (final judgment)

Sarah F. George, Chittenden County State’s Attorney, and Andrew Gilbertson, Deputy State’s Attorney, Burlington, for Plaintiff-Appellee.

Matthew Valerio, Defender General, and Rebecca Turner, Appellate Defender, Montpelier, for Defendant-Appellant.

PRESENT: Reiber, C.J., Eaton, Cohen and Waples, JJ., and Zonay, Supr. J., Specially Assigned

¶ 1. WAPLES, J. Defendant entered a conditional guilty plea to driving under the

influence of alcohol (DUI) and he challenges the court’s denial of his motion to suppress his

evidentiary breath-test result. We affirm.

I. Procedural History

¶ 2. Defendant was charged with DUI following a single-car accident. He moved to

suppress the results of his evidentiary breath test, arguing that he did not knowingly agree to take

the test; he was coerced into taking it; and he was denied his statutory right to meaningfully consult

with counsel. The State opposed the motion.

¶ 3. Following a May 2023 hearing at which defendant and the on-call attorney testified,

the court denied the motion. The court found the following facts, which were essentially undisputed. Defendant was involved in a single-car motor-vehicle accident. He was arrested on

suspicion of DUI and transported to the police station. The arresting officer read the implied

consent form to defendant, including informing defendant of his statutory right to “consult an

attorney” before deciding whether to submit to an evidentiary breath test. 23 V.S.A. § 1202(c).

¶ 4. Defendant consulted privately with the on-call attorney, who asked the processing

officer if defendant had any prior DUI convictions. The officer responded, erroneously, that

defendant had one prior DUI. In fact, although defendant was previously charged with DUI, he

ultimately instead pled guilty to negligent operation. There was no evidence or argument that the

officer intentionally misled the on-call attorney. Based on the information provided by the officer,

the on-call attorney advised defendant to submit to the test. The court credited defendant’s

testimony that he had a “fuzzy” recollection of his prior case, and that he planned to refuse the

evidentiary test, but changed his mind based on the on-call attorney’s advice.1

¶ 5. In his motion to suppress, defendant argued that he submitted to the breath test only

because the arresting officer reported inaccurately to the on-call attorney that he had a prior DUI

conviction. As a result of this mistake, defendant stated that he was led to believe that he could be

found guilty of criminal refusal if he declined to submit to the test, when in fact he could not have

been. See 23 V.S.A. § 1201(b) (providing that “person who has previously been convicted of a

violation of this section shall not operate . . . any vehicle on a highway and refuse a law

enforcement officer’s reasonable request under the circumstances for an evidentiary test where the

officer had reasonable grounds to believe” that person is driving under influence). Under these

circumstances, defendant argued that his decision to take the breath test was not made knowingly;

it was coerced; and it was made without an opportunity to meaningfully consult with an attorney

in violation of 23 V.S.A. § 1202(c).

1 According to the charging affidavit, the breath-test results indicated that defendant’s blood-alcohol content was 0.121. 2 ¶ 6. The trial court concluded that this case fell squarely within the holding of State v.

Fredette, 167 Vt. 586, 705 A.2d 548 (1997) (mem.), in which this Court reversed suppression of

DUI breath test results under factual circumstances similar to this case. See infra, ¶¶ 10-13

(discussing Fredette). The trial court concluded that Fredette disposed of defendant’s claim that

he was denied a meaningful opportunity to consult with counsel. Fredette also disposed of

defendant’s claim that, because his attorney received incorrect information, he did not

“knowingly” decide to submit to the test. The court did not consider defendant’s assertion that his

decision to take the breath test was coerced, explaining that defendant provided no legal authority

for the proposition that evidence obtained by police because of unintentional misdirection

constituted coercion. The court thus denied the motion to suppress.

¶ 7. Defendant moved for reconsideration, asking the court to reach his coercion

argument. Defendant noted that he had cited State v. Edelman, 2018 VT 100, 208 Vt. 372, 198

A.3d 556, which recognizes that a defendant could argue that his consent to a breath test was

“coerced by threats or force.” Id. ¶ 10 (quotation omitted). The court denied the motion,

reiterating that defendant provided no case law reflecting that providing unintentionally inaccurate

information amounted to legal coercion. Defendant entered a conditional guilty plea to DUI and

this appeal followed.

II. Arguments on Appeal

¶ 8. “In reviewing a motion to suppress, we review the trial court’s legal conclusions de

novo and its findings of fact under a clearly erroneous standard.” State v. Ford, 2007 VT 107, ¶ 4,

182 Vt. 421, 940 A.2d 687. Where, as here, defendant challenges only the legal conclusions of

the trial court, our review is “nondeferential and plenary.” State v. Bryant, 2008 VT 39, ¶ 9, 183

Vt. 355, 950 A.2d 467.

3 A. Meaningful Opportunity to Consult with Attorney

¶ 9. We begin by addressing defendant’s argument that he was denied his right to a

meaningful opportunity to consult with counsel because the officer incorrectly told his attorney

that he had a prior DUI conviction. Under Vermont law, a person suspected of DUI has a statutory

right to consult with an attorney before taking an evidentiary breath test requested by a law

enforcement officer. Section 1202(c) of Title 23 provides:

A person who is requested by a law enforcement officer to submit to an evidentiary test or tests has a right as limited in this subsection to consult an attorney before deciding whether or not to submit to such a test or tests. The person must decide whether or not to submit to the evidentiary test or tests within a reasonable time and not later than 30 minutes after the time of the initial attempt to contact the attorney. The person must make a decision about whether to submit to the test or tests at the expiration of the 30 minutes, regardless of whether a consultation took place.

See also id. § 1202(d)(4) (providing that “[a]t the time a test is requested,” police must inform

person of this limited right to consult attorney).

¶ 10. We assessed the scope of the right provided by § 1202(c) in State v. Fredette, 167

Vt. at 587-88, 705 A.2d at 549-50. There, a police officer erroneously told the on-call attorney

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