Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 1921 (2026)

✓ current as of May 2026
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Subchapter 001 : CONTRACTORS' LIENS FOR LABOR OR MATERIAL

(Cite as: 9 V.S.A. § 1921)
Notes of Decisions
Cited in 25 cases (4 in the last 5 years), 1972–2024 · leading case: Newport Sand & Gravel Co. v. Miller Concrete Constr., Inc., 614 A.2d 395 (Vt. 1992).
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Newport Sand & Gravel Co. v. Miller Concrete Constr., Inc., 614 A.2d 395 (Vt. 1992). · cites it 10× “Newport filed a notice of lien against the District on December 11, 1987, under 9 V.S.A. § 1921. At that time, the District owed Simpson, the general contractor, over $900,000.”
Dj Painting, Inc. v. Baraw Enter., Inc., 776 A.2d 413 (Vt. 2001). · cites it 3× “Plaintiff filed a lien against Baraw’s property in October 1998 pursuant to 9 V.S.A. § 1921, and simultaneously filed suit against both defendants in superior court.”
T. A. Haigh Lumber Co. v. Drinkwine, 287 A.2d 560 (Vt. 1972). · cites it 18× “Such notice of intention to claim a lien, says the plaintiff, under the provisions of 9 V.S.A. § 1921 (b) is not required to be recorded.”
Glinka v. Hinesburg Sand & Gravel, Inc. (In Re APC Constr., Inc.), 132 B.R. 690 (D. Vt. 1991). · cites it 5× “On January 24, 1989, Hinesburg recorded a notice of lien for Materials and Labor Furnished under 9 V.S.A. §§ 1921, 1923 on the Town of Col-chester’s property that was improved by the silt.”
Town of Colchester v. Hinesburg Sand & Gravel, Inc. (In Re APC Constr., Inc.), 112 B.R. 89 (Bankr. D. Vt. 1990). · cites it 4× “§ 1921(b) is not such as to give notice to the world of the lien upon the property which the claimant of the lien seeks to establish but to place the owner of the property upon notice that if he seeks to alienate the property upon which the lien may be claimed he may suffer…”
Birchwood Land Co., Inc. v. Ormond Bushey & Sons, Inc., 2013 VT 60 (Vt. 2013). · cites it 2× “” 9 V.S.A. § 1921(a). The statute defines the lot of land as “all of the land owned or held by the owner and used or designed for use in connection with such improvements, but such lien shall not extend to other adjacent lands used for purposes of profit.”
In Re Rainbow Trust, 216 B.R. 77 (2d Cir. BAP 1997). · cites it 6× “See Vermont's contractor's lien statute, 9 V.S.A. § 1921, et seq. On March 11, 1993, Moulton commenced an action in the Superior Court of Vermont against Rainbow Trust for foreclosure of lien, breach of contract, and quantum meruit.”
Johnson v. Harwood, 2008 VT 4 (Vt. 2008). “See 9 V.S.A. § 1921. 2 Although defendant’s motion for summary judgment was unsworn and unaccompanied by affidavits, plaintiff did not oppose the motion on this basis, but instead disputed the facts contained in the unsworn statement by reference to his own verified complaint.”
Morrisville Lumber Co., Inc. v. Okcuoglu, 531 A.2d 887 (Vt. 1987). “Plaintiff’s second argument is that it is entitled to equitable relief because defendants have been unjustly enriched through the use of materials that are now part of defendants’ home, and because the contractor’s lien statute, 9 V.S.A. § 1921, does not provide an adequate…”
Naylor v. Cusson, 412 B.R. 646 (D. Vt. 2009). · cites it 2× “Vt. Stat. Ann. tit. 9, §§ 1921 (a). Any contractor who does shall have a lien to secure payment by giving written notice of the lien to the property owner.”
In Re Ahokas, 361 B.R. 54 (Bankr. D. Vt. 2007). · cites it 2× “The question presented in the instant case is whether a judgment lien that includes (1) a jury award arising from the Contractor’s Lien Law 1 , 9 V.S.A. § 1921 et seq., and (2) an award for attorney’s fees, costs, and penalties arising under the Vermont Prompt Payment Act, 9 V.”
Bernstein v. Held (In Re Bernstein), 62 B.R. 545 (Bankr. D. Vt. 1986). “Dern introduced no evidence as to when its lien was perfected under 9 V.S.A. Section 1921, et seq. although from the pleading we know it to be June 20,1980.”
Show all 25 citing cases →
— Vt. Stat. Ann. tit. 09, § 1921(a) — 10 cases
Glinka v. Hinesburg Sand & Gravel, Inc. (In Re APC Constr., Inc.), 132 B.R. 690 (D. Vt. 1991). “On January 24, 1989, Hinesburg recorded a notice of lien for Materials and Labor Furnished under 9 V.S.A. §§ 1921, 1923 on the Town of Col-chester’s property that was improved by the silt.”
Birchwood Land Co., Inc. v. Ormond Bushey & Sons, Inc., 2013 VT 60 (Vt. 2013). “” 9 V.S.A. § 1921(a). The statute defines the lot of land as “all of the land owned or held by the owner and used or designed for use in connection with such improvements, but such lien shall not extend to other adjacent lands used for purposes of profit.”
In Re Rainbow Trust, 216 B.R. 77 (2d Cir. BAP 1997). “See Vermont's contractor's lien statute, 9 V.S.A. § 1921, et seq. On March 11, 1993, Moulton commenced an action in the Superior Court of Vermont against Rainbow Trust for foreclosure of lien, breach of contract, and quantum meruit.”
In Re Ahokas, 361 B.R. 54 (Bankr. D. Vt. 2007). “The question presented in the instant case is whether a judgment lien that includes (1) a jury award arising from the Contractor’s Lien Law 1 , 9 V.S.A. § 1921 et seq., and (2) an award for attorney’s fees, costs, and penalties arising under the Vermont Prompt Payment Act, 9 V.”
In Re Summit Ventures, Inc., 135 B.R. 483 (Bankr. D. Vt. 1991).
— Vt. Stat. Ann. tit. 09, § 1921(b) — 6 cases
Newport Sand & Gravel Co. v. Miller Concrete Constr., Inc., 614 A.2d 395 (Vt. 1992). “Newport filed a notice of lien against the District on December 11, 1987, under 9 V.S.A. § 1921. At that time, the District owed Simpson, the general contractor, over $900,000.”
Town of Colchester v. Hinesburg Sand & Gravel, Inc. (In Re APC Constr., Inc.), 112 B.R. 89 (Bankr. D. Vt. 1990). “§ 1921(b) is not such as to give notice to the world of the lien upon the property which the claimant of the lien seeks to establish but to place the owner of the property upon notice that if he seeks to alienate the property upon which the lien may be claimed he may suffer…”
T. A. Haigh Lumber Co. v. Drinkwine, 287 A.2d 560 (Vt. 1972). “Such notice of intention to claim a lien, says the plaintiff, under the provisions of 9 V.S.A. § 1921 (b) is not required to be recorded.”
Glinka v. Hinesburg Sand & Gravel, Inc. (In Re APC Constr., Inc.), 132 B.R. 690 (D. Vt. 1991). “On January 24, 1989, Hinesburg recorded a notice of lien for Materials and Labor Furnished under 9 V.S.A. §§ 1921, 1923 on the Town of Col-chester’s property that was improved by the silt.”
Allen v. Feeney Prop. (Vt. Super. Ct. 2024).
— Vt. Stat. Ann. tit. 09, § 1921(c) — 5 cases
T. A. Haigh Lumber Co. v. Drinkwine, 287 A.2d 560 (Vt. 1972). “Such notice of intention to claim a lien, says the plaintiff, under the provisions of 9 V.S.A. § 1921 (b) is not required to be recorded.”
Glinka v. Hinesburg Sand & Gravel, Inc. (In Re APC Constr., Inc.), 132 B.R. 690 (D. Vt. 1991). “On January 24, 1989, Hinesburg recorded a notice of lien for Materials and Labor Furnished under 9 V.S.A. §§ 1921, 1923 on the Town of Col-chester’s property that was improved by the silt.”
Town of Colchester v. Hinesburg Sand & Gravel, Inc. (In Re APC Constr., Inc.), 112 B.R. 89 (Bankr. D. Vt. 1990). “§ 1921(b) is not such as to give notice to the world of the lien upon the property which the claimant of the lien seeks to establish but to place the owner of the property upon notice that if he seeks to alienate the property upon which the lien may be claimed he may suffer…”
In Re Rainbow Trust, 216 B.R. 77 (2d Cir. BAP 1997). “See Vermont's contractor's lien statute, 9 V.S.A. § 1921, et seq. On March 11, 1993, Moulton commenced an action in the Superior Court of Vermont against Rainbow Trust for foreclosure of lien, breach of contract, and quantum meruit.”
Wardwell v. Metilly, 253 B.R. 512 (D. Vt. 2000).
— Vt. Stat. Ann. tit. 09, § 1921(d) — 1 case
T. A. Haigh Lumber Co. v. Drinkwine, 287 A.2d 560 (Vt. 1972). “Such notice of intention to claim a lien, says the plaintiff, under the provisions of 9 V.S.A. § 1921 (b) is not required to be recorded.”
— Vt. Stat. Ann. tit. 09, § 1921(e) — 2 cases
Birchwood Land Co., Inc. v. Ormond Bushey & Sons, Inc., 2013 VT 60 (Vt. 2013). “” 9 V.S.A. § 1921(a). The statute defines the lot of land as “all of the land owned or held by the owner and used or designed for use in connection with such improvements, but such lien shall not extend to other adjacent lands used for purposes of profit.”
Birchwood Land Dev. Corp. v. Ormond Bushey & Sons, Inc. (Vt. Super. Ct. 2011).
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