State v. Loveland
In State v. Loveland, 165 Vt. 418, 684 A.2d 272 (1996) the Court acknowledged that Cate dealt with a very narrow situation, but nevertheless extended its holding to apply to statements made by sex offenders at sentencing.
The Court concluded that if such statements were required for successful completion of probation, they would be inadmissible at any subsequent criminal proceeding. Id. at 427, 684 A.2d at 278.
In that case, the Court remanded the matter for resentencing because the defendant's desire to protect his privilege against self-incrimination may have deterred him from making a statement at his sentencing hearing concerning his willingness to accept responsibility for his crime and thus successfully engage in a probationary sex offender treatment program. Id. at 427, 684 A.2d at 279.