DNA-Based Exoneration as the Exclusive Gateway to VIPA Compensation:
A Comprehensive Commentary on Stanley Reynolds v. State of Vermont, 2025 VT 34

1. Introduction

In Reynolds v. State of Vermont, the Vermont Supreme Court confronted a crucial statutory-interpretation question: does the Vermont Innocence Protection Act (VIPA), 13 V.S.A. §§ 5561-5585, allow damages suits by anyone whose conviction has been vacated, or only by those exonerated through DNA testing? Stanley Reynolds, whose 2012 sexual-assault conviction was vacated on ineffective-assistance grounds, sought over \$400,000 in compensation for more than eight years in prison. The Superior Court dismissed his suit; he appealed; and, during the appeal, he died, prompting a survivorship dispute.

The Supreme Court (Cohen, J.) both denied the State’s motion to dismiss the appeal as moot and affirmed dismissal on the merits, holding that VIPA’s compensation remedy is available exclusively to persons exonerated through the DNA-testing process set out in Subchapter 1 of Chapter 182. This decision crystallises a new precedent on statutory scope and survivors’ rights in wrongful-conviction claims.

2. Summary of the Judgment

1. Survivorship: Wrongful-imprisonment claims under VIPA survive the claimant’s death, because they are analogous to the common-law tort of false imprisonment, which Vermont’s survival statute, 14 V.S.A. § 1452, expressly preserves.
2. Statutory Interpretation: The plain text of VIPA—particularly §§ 5572, 5576, and 5577—ties compensation to exoneration “pursuant to this chapter,” and the only exoneration mechanism “in this chapter” (Chapter 182) is Subchapter 1’s DNA-testing procedure.
3. Result: Because Reynolds’ conviction was vacated for ineffective assistance of counsel—not DNA evidence—he fell outside the statutory class; his complaint was properly dismissed under V.R.C.P. 12(c).

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

• Administrator of Whitcomb’s Estate v. Cook, 38 Vt. 477 (1866)
  Key for survivorship. The Court analogised VIPA claims to the false-imprisonment action that survived the plaintiff’s death in Whitcomb, thus rejecting the State’s mootness argument.
• Mullinnex v. Menard, 2020 VT 33; Paige v. State, 2017 VT 54
  Reiterated the Court’s independent duty to police subject-matter jurisdiction and to dismiss moot cases.
• Island Industries, LLC v. Town of Grand Isle, 2021 VT 49
  Standard of de novo review for Rule 12(c) judgments.
• Canons of Vermont statutory interpretation (e.g., Maple Run USD v. Vt. HRC, 2023 VT 63; Town of Pawlet v. Banyai, 2022 VT 4)
  Cited for “plain-language rule” and integrated reading of the statute as a whole.

3.2 The Court’s Legal Reasoning

1. Step 1: Identify Survival
   • 14 V.S.A. § 1452 preserves claims for “bodily hurt or injury.”
   • Whitcomb construed “injury” broadly to include illegal confinement without violence.
   • Therefore, Reynolds’ estate retained a live controversy; appeal proceeds.
2. Step 2: Apply Plain-Language Canon to VIPA
   • § 5572(a) grants a cause of action to persons “exonerated pursuant to this chapter.” The phrase “this chapter” = Chapter 182.
   • Within Chapter 182, only Subchapter 1 (DNA testing) creates an exoneration path.
   • Additional references in §§ 5576 & 5577 to “pursuant to subchapter 1” reinforce exclusivity.
3. Step 3: Reject Broader Reading
   • The Court declined to view §§ 5573(a)(2) & 5574(a)(2) as opening the door to any vacatur/ dismissal/ pardon; they merely identify events that trigger the limitations period once a DNA-based exoneration occurs.
   • Because the statutory text was “clear and unambiguous,” legislative-history and policy arguments were unnecessary (Pawlet rule).

3.3 Expected Impact of the Decision

Narrow Eligibility under VIPA
After Reynolds, claimants whose convictions are vacated for Brady violations, complaints of police misconduct, recantations, new alibi evidence, or ineffective assistance—but without new DNA proof of innocence—cannot use VIPA to obtain compensation. They must:

• Pursue ordinary civil-rights actions (42 U.S.C. § 1983) or state-law torts (false imprisonment, malicious prosecution), often requiring proof of official misconduct and facing sovereign-immunity hurdles, or
• Seek legislative claims bills on a case-by-case basis.

Legislative Pressure
The decision clarifies statutory limitations, likely catalysing legislative efforts to amend VIPA if policymakers wish to cover a broader innocence class. Neighboring states—e.g., Massachusetts and New Hampshire—already provide compensation without a DNA prerequisite; Vermont now diverges explicitly.

4. Complex Concepts Simplified

• VIPA: Two-track statute (Subchapter 1 = DNA testing; Subchapter 2 = damages). The judgment says the second track is only triggered if the first track was used.
• Exoneration vs. Vacatur: • Vacatur = conviction erased (could be procedural). • Exoneration = legal declaration of actual innocence. The Court fuses the two by requiring vacatur because of DNA-proven innocence.
• Survivorship Statutes: Laws (14 V.S.A. §§ 1451-1452) deciding whether a lawsuit lives on after a party dies. Vermont allows most personal-injury torts—including wrongful confinement—to survive.
• Rule 12(c) Judgment on the Pleadings: A procedural device letting courts decide legal questions assuming all facts in the complaint are true; no discovery or trial needed if the law plainly forecloses relief.

5. Conclusion

Reynolds v. State of Vermont cements a bright-line rule: DNA-generated exoneration is the exclusive trigger for VIPA compensation. The Court reaffirmed the robust reach of Vermont’s survivorship statute while constraining wrongful-conviction damages to the statutory mechanisms expressly provided by the Legislature. The ruling illuminates the interplay between plain-language interpretation and public-policy aspirations: where statutory text is unambiguous, the judiciary will not expand eligibility, leaving reform to lawmakers. Future litigants must therefore pursue alternative avenues—or lobby for statutory amendment—when DNA evidence is absent.