Girouard v. Hogan
In Girouard v. Hogan, 135 Vt. 448, 378 A.2d 105 (1977), the Court rejected a Vermont inmate's claim that his planned transfer to an out-of-state federal facility constituted the "punishment of exile, banishment or transportation." Id. at 449, 378 A.2d at 106.
The Court concluded that the analogy "outruns the realities. . . . The fact that the confinement may take place outside of the State of Vermont is merely a fortuitous consequence of a properly invoked administrative decision and not a designed denial of the State of Vermont to him imposed as a penalty." Id. at 449-50, 378 A.2d at 106-07.