Doe v. Salmon
In Doe v. Salmon, 135 Vt. 443, 378 A.2d 512 (Vt 1977), the Governor made agreements with some pardon recipients that their pardons would remain private in the interests of the individual's privacy.
The Court concluded that "those agreements, although compassionately entered into, could only be valid if authorized by law, and there is no such law." Id. at 516.
Likewise, the Court concluded while the Governor had the constitutional power to grant pardons, that constitutional power did not extend to ordering them to be sealed.