Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 4002 (2026)

✓ current as of May 2026
Find cases: SyfertCases citing this section VT-LEGlegislature.vermont.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
(Cite as: 9 V.S.A. § 4002)
Notes of Decisions
Cited in 15 cases (6 in the last 5 years), 2002–2026 · leading case: Fletcher Hill, Inc. v. Crosbie, 2005 VT 1 (Vt. 2005).
Sort: Relevance Newest Treatment
Fletcher Hill, Inc. v. Crosbie, 2005 VT 1 (Vt. 2005). · cites it 3× “For example, pursuant to 9 V.S.A. § 4002(d), payments to the contractor delayed beyond the due date will accrue interest, beginning on the twenty-first day, at a rate equal to that established by 12 V.”
Donald L. Sweet, Jr. & Preston L. Sweet v. Roy A. St. Pierre & Catherine St. Pierre d/b/a Woodlands Farms, 201 A.3d 978 (Vt. 2018). · cites it 2× “See 9 V.S.A. § 4002(a) ("The owner shall pay the contractor strictly in accordance with the terms of the construction contract.”
Birchwood Land Co., Inc. v. Ormond Bushey & Sons, Inc., 2013 VT 60 (Vt. 2013). · cites it 3× “Further, if the owner unreasonably withholds acceptance of work and fails to pay, the owner i is subject to payment of interest, a penalty, and attorney’s fees. Id. § 4005(d).”
Elec. Man, Inc. v. Charos, 895 A.2d 193 (Vt. 2006). “9 V.S.A. § 4002(b), (c). Contractor claimed that his lawyer’s letter of January 2002 was an invoice under the statute, and it sought a progress payment covering both labor and materials.”
Reed v. Zurn, 2010 VT 14 (Vt. 2010). “Defendants rely upon 9 V.S.A. § 4002(b), which states that unless otherwise provided in the construction contract, “the contractor shall be entitled to invoice the owner for progress payments at the end of the billing period.”
J.A. McDonald, Inc. v. Waste Sys. Int'l Moretown Landfill, Inc., 247 F. Supp. 2d 542 (D. Vt. 2002). “Moreover, in this case McDonald demanded prejudgment interest pursuant to the penalty provisions of the Vermont Prompt Payment Act, Vt. Stat. Ann tit. 9, §§ 4002(d), 4007(b).”
Lacillade's v. Dreslin (Vt. Super. Ct. 2025). · cites it 2× “Thus, whereas Lacillade’s, as the contractor, may be entitled to a 1% per month statutory penalty for Dreslin’s failure to comply with the payment terms of the PPA, id.”
Allen v. Feeney Prop. (Vt. Super. Ct. 2024). “In construction cases, homeowners are typically obligated by the Vermont Prompt Payment Act to pay their contractor “strictly in accordance with the terms of the construction contract,” and to pay periodic invoices that are submitted along the way.”
Facility Gateway Corp. v. Sovernet, Inc. (Vt. Super. Ct. 2017). “However, an owner may withhold payment from a contractor “in an amount equaling the value of any good faith claims against an invoicing contractor or subcontractor, including claims arising from unsatisfactory job progress, defective construction, disputed work, or third-party…”
Troy Boiler Works, Inc. v. Long Falls Paperboard, LLC (D. Vt. 2022). “” 9 V.S.A. § 4002(a); see Birchwood Land Co.”
Kerr v. Clark (Vt. Super. Ct. 2026). “See 9 V.S.A. §§ 4002, 4003. The Legislature enacted the Act to ensure "the Prompt Payment of Construction Invoices.”
Turk v. Ecowood Floors (Vt. Super. Ct. 2026). “” 9 V.S.A. § 4002(c). The Vermont Supreme Court, however, has rejected the premise that the Prompt Pay Act conditions its application upon the submission of particular invoices.”
Show all 15 citing cases →
— Vt. Stat. Ann. tit. 09, § 4002(a) — 7 cases
Donald L. Sweet, Jr. & Preston L. Sweet v. Roy A. St. Pierre & Catherine St. Pierre d/b/a Woodlands Farms, 201 A.3d 978 (Vt. 2018). “See 9 V.S.A. § 4002(a) ("The owner shall pay the contractor strictly in accordance with the terms of the construction contract.”
Birchwood Land Co., Inc. v. Ormond Bushey & Sons, Inc., 2013 VT 60 (Vt. 2013). “Further, if the owner unreasonably withholds acceptance of work and fails to pay, the owner i is subject to payment of interest, a penalty, and attorney’s fees. Id. § 4005(d).”
Allen v. Feeney Prop. (Vt. Super. Ct. 2024). “In construction cases, homeowners are typically obligated by the Vermont Prompt Payment Act to pay their contractor “strictly in accordance with the terms of the construction contract,” and to pay periodic invoices that are submitted along the way.”
Facility Gateway Corp. v. Sovernet, Inc. (Vt. Super. Ct. 2017). “However, an owner may withhold payment from a contractor “in an amount equaling the value of any good faith claims against an invoicing contractor or subcontractor, including claims arising from unsatisfactory job progress, defective construction, disputed work, or third-party…”
Troy Boiler Works, Inc. v. Long Falls Paperboard, LLC (D. Vt. 2022). “” 9 V.S.A. § 4002(a); see Birchwood Land Co.”
— Vt. Stat. Ann. tit. 09, § 4002(b) — 3 cases
Donald L. Sweet, Jr. & Preston L. Sweet v. Roy A. St. Pierre & Catherine St. Pierre d/b/a Woodlands Farms, 201 A.3d 978 (Vt. 2018). “See 9 V.S.A. § 4002(a) ("The owner shall pay the contractor strictly in accordance with the terms of the construction contract.”
Elec. Man, Inc. v. Charos, 895 A.2d 193 (Vt. 2006). “9 V.S.A. § 4002(b), (c). Contractor claimed that his lawyer’s letter of January 2002 was an invoice under the statute, and it sought a progress payment covering both labor and materials.”
Reed v. Zurn, 2010 VT 14 (Vt. 2010). “Defendants rely upon 9 V.S.A. § 4002(b), which states that unless otherwise provided in the construction contract, “the contractor shall be entitled to invoice the owner for progress payments at the end of the billing period.”
— Vt. Stat. Ann. tit. 09, § 4002(c) — 2 cases
Turk v. Ecowood Floors (Vt. Super. Ct. 2026). “” 9 V.S.A. § 4002(c). The Vermont Supreme Court, however, has rejected the premise that the Prompt Pay Act conditions its application upon the submission of particular invoices.”
Turk v. Ecowood Floors (Vt. Super. Ct. 2026).
— Vt. Stat. Ann. tit. 09, § 4002(d) — 4 cases
Fletcher Hill, Inc. v. Crosbie, 2005 VT 1 (Vt. 2005). “For example, pursuant to 9 V.S.A. § 4002(d), payments to the contractor delayed beyond the due date will accrue interest, beginning on the twenty-first day, at a rate equal to that established by 12 V.”
Birchwood Land Co., Inc. v. Ormond Bushey & Sons, Inc., 2013 VT 60 (Vt. 2013). “Further, if the owner unreasonably withholds acceptance of work and fails to pay, the owner i is subject to payment of interest, a penalty, and attorney’s fees. Id. § 4005(d).”
J.A. McDonald, Inc. v. Waste Sys. Int'l Moretown Landfill, Inc., 247 F. Supp. 2d 542 (D. Vt. 2002). “Moreover, in this case McDonald demanded prejudgment interest pursuant to the penalty provisions of the Vermont Prompt Payment Act, Vt. Stat. Ann tit. 9, §§ 4002(d), 4007(b).”
Lacillade's v. Dreslin (Vt. Super. Ct. 2025). “Thus, whereas Lacillade’s, as the contractor, may be entitled to a 1% per month statutory penalty for Dreslin’s failure to comply with the payment terms of the PPA, id.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.