Vermont
Vermont Voyeurism Laws
Independently fact-checked against primary sources (last audited August 15, 2026). · Reviewed by the RecordingLaw editorial team. · Law checked current as of August 15, 2026. · 4 primary sources cited on this page. How we verify our legal content
Vermont criminalizes voyeurism under 13 V.S.A. 2605, prohibiting intentional viewing, photographing, or recording of a person's intimate areas without consent wherever a reasonable expectation of privacy exists. A first offense carries up to two years in prison; displaying or disclosing a recorded image to a third party carries up to five years, regardless of the victim's age.
Vermont addresses voyeurism and hidden camera offenses through two primary statutes: 13 V.S.A. 2605 (voyeurism) and 13 V.S.A. 2606 (nonconsensual disclosure of intimate images). Vermont Supreme Court case law, particularly State v. Geraw (2002), provides additional protections against hidden recording in private homes.
This guide covers what conduct is prohibited, criminal penalties, the interaction with federal law, and remedies for victims.
Vermont Voyeurism Statute (13 V.S.A. 2605)
What the Law Prohibits
A person commits voyeurism by intentionally viewing, photographing, filming, or recording a person's intimate areas without their consent in circumstances where the person has a reasonable expectation of privacy. The law applies regardless of whether the person is in a public or private setting.
Criminal Penalties
| Offense | Maximum Prison | Maximum Fine |
|---|---|---|
| First offense | 2 years | $1,000 |
| Second or subsequent | 3 years | $5,000 |
| Displaying/disclosing recorded image to a third party (13 V.S.A. 2605(c)) | 5 years | $5,000 |
Nonconsensual Intimate Images (13 V.S.A. 2606)
Knowingly disclosing images of an identifiable person who is nude or engaged in sexual conduct, without consent, with intent to harm, harass, intimidate, threaten, or coerce.
| Offense | Maximum Prison | Maximum Fine |
|---|---|---|
| Standard | 2 years | $2,000 |
| For profit | 5 years | $10,000 |
2024 Deepfake Amendment (Act 161)
Act 161 of 2024 (H.878), signed June 6, 2024, amended 13 V.S.A. 2606 to cover digitized and synthetic intimate images. AI-generated deepfakes that depict an identifiable person in a sexual manner are now expressly covered. The amendment added a definition of "digitization" to bring computer-generated intimate imagery within the statute's scope.
Federal TAKE IT DOWN Act
The TAKE IT DOWN Act, signed May 19, 2025 (Pub. L. 119-12), requires online platforms to remove nonconsensual intimate imagery -- including AI-generated deepfakes -- within 48 hours of receiving a victim's request; that platform compliance duty took effect May 19, 2026. Federal criminal penalties apply to the creation and distribution of such images. This law operates alongside Vermont's 13 V.S.A. 2606 and provides an additional federal removal remedy.
Hidden Cameras and State v. Geraw
The Vermont Supreme Court ruled in State v. Geraw (2002) that placing hidden recording devices inside a private home without consent or a warrant violates Article 11 of the Vermont Constitution. This is the strongest privacy protection against hidden cameras in Vermont, applying to all recording in private residences.
Where Protections Apply
Strong privacy expectation: Private homes (Geraw), hotel rooms, bathrooms, locker rooms, changing rooms, medical examination rooms.
No privacy expectation: Public parking lots (State v. Brooks, 157 Vt. 490 (1991)), hospital ERs (Rheaume), public streets, stores.
Federal Law Interaction
The Video Voyeurism Prevention Act (18 U.S.C. 1801) applies on federal property. Federal wiretap law (18 U.S.C. 2511) applies to audio captured by hidden cameras.
Reporting
Contact local law enforcement. Do not disturb hidden devices. Document details. Consult an attorney about civil claims including invasion of privacy and intentional infliction of emotional distress.
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Frequently Asked Questions
Is voyeurism a felony in Vermont?
Voyeurism is punishable by up to 2 years for a first offense, or up to 5 years if the recorded image is displayed or disclosed to a third party. Nonconsensual disclosure of intimate images for profit carries up to 5 years.
Are hidden cameras illegal in Vermont?
Hidden cameras are illegal in private homes under State v. Geraw and in any location where someone has a reasonable expectation of privacy under 13 V.S.A. 2605.
Does Vermont law cover deepfakes and AI-generated intimate images?
Yes. Act 161 of 2024 amended 13 V.S.A. 2606 to cover digitized and synthetic intimate images, including AI-generated deepfakes. The federal TAKE IT DOWN Act, signed May 19, 2025, also requires platforms to remove such content within 48 hours of a victim's request; that platform duty took effect May 19, 2026.
Does Vermont have a revenge porn law?
Yes. 13 V.S.A. 2606 criminalizes nonconsensual disclosure of intimate images with up to 2 years imprisonment, or 5 years if done for profit. The 2024 deepfake amendment extended this to AI-generated imagery.
What should I do if I find a hidden camera in Vermont?
Contact law enforcement. Do not disturb the device. Document everything. Consult an attorney about civil remedies.
Can my landlord install cameras in my apartment in Vermont?
No. Under State v. Geraw, hidden recording devices in private homes violate Article 11. Your rental unit is a private home.
Updates
Corrected the federal TAKE IT DOWN Act's signing date from May 19, 2026 to the actual May 19, 2025 (2026 is the platform compliance deadline, which has now passed), and added the correct reporter citation and source link for State v. Brooks.
Independently fact-checked against the cited primary sources; governing law re-checked for recent changes
Governing law re-checked for recent changes
Corrected the 13 V.S.A. 2605(c) penalty: the 5-year/$5,000 tier applies to displaying or disclosing a recorded image to a third party, not to offenses involving minors (the statute has no minors-based enhancement).
Governing law re-checked for recent changes
Reviewed and approved by an editor
The Law Behind This Article
This article rests on the statutory provisions below, held in our own legal record and retrieved from the official source. Tap a section to read the operative text.
Vermont Statutes Annotated, Title 13: Crimes and Criminal Procedure, Chapter 59: Lewdness and Prostitution, Subchapter: LEWD AND INDECENT CONDUCT
§ 2605VoyeurismIn forcecited in 14 of our articles
(a) As used in this section: (1) “Bona fide private investigator or bona fide security guard” means an individual lawfully providing services, whether licensed or unlicensed, pursuant to 26 V.S.A. §§ 3151 and 3151a. (2) “Female breast” means any portion of the female breast below the top of the areola. (3) “Circumstances in which a person has a reasonable expectation of privacy” means circumstances in which a reasonable person would believe that his or her intimate areas would not be visible to the public, regardless of whether that person is in a public or private area. This definition includes circumstances in which a person knowingly disrobes in front of another, but does not expect nor give consent for the other person to photograph, film, or record his or her intimate areas. (4) “Intimate areas” means the naked or undergarment-clad genitals, pubic area, buttocks, or female breast of a person.
Official text (excerpt) · last checked 2026-08-31 · Read the full text in our law library · Verify at legislature.vermont.gov
Cited in 6 court opinions in our collectionLatest citing opinion in our collection: 2022
In the courts (editorial summary, independently checked):In State v. DEVOID (2010) the Vermont Supreme Court reversed an attempted voyeurism conviction under section 2605(b)(1), holding the evidence could not show the defendant, on the ground, was able to see the complainant's intimate areas as the statute defines them, so looking at her window was not an overt act.
Opinions citing this section in our collection:
- State v. DEVOID (Supreme Court of Vermont 2010, 188 Vt. 445)✓A man stared up at a second-floor shower window from the parking lot; a photograph taken inside the bathroom showed the complainant's intimate areas, as the statute defines them, were below the sill, so the court reversed his attempted-voyeurism conviction as unsupported.
- State v. Squiers (Supreme Court of Vermont 2006, 179 Vt. 388)“…r any object into the genital or anal opening of another”); 13 V.S.A. § 2605(a)(4) & (b) (prohibiting the viewing or…”
- State v. Beaudoin (Supreme Court of Vermont 2008, 185 Vt. 164)“…ter 1 includes §§ 2601 and 2602 and a section on voyeurism, 13 V.S.A. § 2605. Section 2601 makes it a felony to enga…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 2606Disclosure of sexually explicit images without consentIn forcecited in 9 of our articles
(a) As used in this section: (1) “Disclose” includes transfer, publish, distribute, exhibit, or reproduce. (2) “Harm” means physical injury, financial injury, or serious emotional distress. (3) “Nude” means any one or more of the following uncovered parts of the human body: (A) genitals; (B) pubic area; (C) anus; or (D) post-pubescent female nipple. (4) “Sexual conduct” shall have the same meaning as in section 2821 of this title. (5) “Visual image” includes a photograph, film, videotape, recording, or digital reproduction, including an image created or altered by digitization. (6) “Digitization” means the process of altering an image in a realistic manner utilizing an image or images of a person, including images other than the person depicted, or computer-generated images. (b)(1) A person violates this section if the person knowingly discloses a visual image of an identifiable person who is nude or who is engaged in sexual conduct, without the person’s consent, with the intent to harm, harass, intimidate, threaten, or coerce the person depicted, and the disclosure would cause a reasonable person to suffer harm.
Official text (excerpt) · last checked 2026-08-30 · Read the full text in our law library · Verify at legislature.vermont.gov
Cited in 3 court opinions in our collectionLatest citing opinion in our collection: 2024
Opinions citing this section in our collection:
- State v. Rebekah S. VanBuren (Supreme Court of Vermont 2019, 2018 VT 95)“…s statute banning disclosure of nonconsensual pornography. 13 V.S.A. § 2606. We conclude that the statute is const…”
- Ava Morton v. Mayah Young (Supreme Court of Vermont 2023, 298 A.3d 230)“…ute criminalizing disclosure of nonconsensual pornography, 13 V.S.A. § 2606, did not violate the First Amendment. I…”
- corriveau v. windham (Vermont Superior Court 2024)“…ithout saying that an injunction is an equitable remedy.”); 13 V.S.A. § 2606(e)(2) (explicitly listing “a preliminar…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
United States Code Title 18
§ 1801Video voyeurismIn forcecited in 79 of our articles
Whoever, in the special maritime and territorial jurisdiction of the United States, has the intent to capture an image of a private area of an individual without their consent, and knowingly does so under circumstances in which the individual has a reasonable expectation of privacy, shall be fined under this title or imprisoned not more than one year, or both. In this section— the term “capture”, with respect to an image, means to videotape, photograph, film, record by any means, or broadcast; the term “broadcast” means to electronically transmit a visual image with the intent that it be viewed by a person or persons; the term “a private area of the individual” means the naked or undergarment clad genitals, pubic area, buttocks, or female breast of that individual; the term “female breast” means any portion of the female breast below the top of the areola; and the term “under circumstances in which that individual has a reasonable expectation of privacy” means— circumstances in which a reasonable person would believe that he or she could disrobe in privacy, without being concerned that an image of a private area of the individual was being captured; or circumstances in which a…
Official text (excerpt) · last checked 2026-07-28 · Read the full text in our law library · Verify at uscode.house.gov
Cited in 53 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):Courts have applied 18 U.S.C. 1801 mainly at its edges. United States v. Johnson (2010) read it as Congress's answer to secretly filming nudity on federal property, acquitting on a child exploitation charge instead. EPIC v. Department of Homeland Security (2011) applied the Section 1801(c) law enforcement exception to a TSA scanner claim.
Opinions citing this section in our collection:
- United States v. Anthony Helton (Court of Appeals for the Fourth Circuit 2019, 944 F.3d 198)“…from this list of federal offenses is video voyeurism under 18 U.S.C. § 1801. Rather than list this statute as an enu…”
- United States v. Johnson (District Court, W.D. Missouri 2010, 719 F. Supp. 2d 1059)✓A weightlifting coach hid a camera to film minors weighing in nude; acquitting him under the child exploitation statute, the court called that conduct plain video voyeurism under section 1801, but noted the section reaches only federal maritime and territorial jurisdiction.
- Electronic Privacy Information Center v. United States Department of Homeland Security (Court of Appeals for the D.C. Circuit 2011, 653 F.3d 1)✓Privacy groups challenged TSA body scanners under the Video Voyeurism Prevention Act; the D.C. Circuit held the statute's exception for lawful law enforcement, correctional, or intelligence activity applied to airport screening, so the section 1801 claim failed.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 2511Interception and disclosure of wire, oral, or electronic communications prohibitedIn forcecited in 418 of our articles
Except as otherwise specifically provided in this chapter any person who— intentionally intercepts, endeavors to intercept, or procures any other person to intercept or endeavor to intercept, any wire, oral, or electronic communication; intentionally uses, endeavors to use, or procures any other person to use or endeavor to use any electronic, mechanical, or other device to intercept any oral communication when— such device is affixed to, or otherwise transmits a signal through, a wire, cable, or other like connection used in wire communication; or such device transmits communications by radio, or interferes with the transmission of such communication; or such person knows, or has reason to know, that such device or any component thereof has been sent through the mail or transported in interstate or foreign commerce; or such use or endeavor to use (A) takes place on the premises of any business or other commercial establishment the operations of which affect interstate or foreign commerce; or (B) obtains or is for the purpose of obtaining information relating to the operations of any business or other commercial establishment the operations of which affect interstate or foreign…
Official text (excerpt) · last checked 2026-08-28 · Read the full text in our law library · Verify at uscode.house.gov
Cited in 2,045 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):Griggs-Ryan v. Smith (1990) applied the Section 2511(2)(d) prior-consent exception, treating a tenant repeatedly told that all incoming calls were taped as having impliedly consented. United States v. United States District Court (1972) read the then-current Section 2511(3) as conferring no presidential surveillance power.
Opinions citing this section in our collection:
- Mitchell v. Forsyth (Supreme Court of the United States 1985, 472 U.S. 511)✓The Attorney General authorized a warrantless 1970 national security wiretap that caught the plaintiff's calls; the Court held the since-repealed Section 2511(3) disclaimer left the tap lawful under Title III, and that Mitchell had qualified immunity.
- United States v. United States District Court for the Eastern District of Michigan (Supreme Court of the United States 1972, 407 U.S. 297)✓The Attorney General approved warrantless wiretaps on members of a domestic group accused of bombing a CIA office; the Court read Section 2511(3) as a congressional disclaimer conferring no surveillance power, then held the Fourth Amendment required prior judicial approval.
- Forsyth v. Barr (Court of Appeals for the Fifth Circuit 1994, 19 F.3d 1527)✓Dallas police used, in an internal affairs probe of an officer, calls private parties allegedly intercepted illegally; assuming that was unlawful, the Fifth Circuit held Section 2517(1) and (2) allowed the disclosure and use, defeating the Section 2511(1)(c) and (d) claims.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
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Sources and References
- 13 V.S.A. 2605 -- Voyeurism(legislature.vermont.gov).gov
- 13 V.S.A. 2606 -- Nonconsensual Disclosure of Intimate Images(legislature.vermont.gov).gov
- Act 161 of 2024 (H.878) -- Deepfake Amendment to 2606(legislature.vermont.gov).gov
- Vermont Constitution -- Article 11(legislature.vermont.gov).gov
- 18 U.S.C. 1801 -- Video Voyeurism Prevention Act(law.cornell.edu)