Vt. Stat. Ann. » Title 12 Chapter 121
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 3169 (2026)

✓ current as of May 2026
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Subchapter 003 : PARTICULAR PROCEEDINGS

(Cite as: 12 V.S.A. § 3169)
Notes of Decisions
Cited in 2 cases, 1987–2014 · leading case: Olson v. Townsend, 530 A.2d 566 (Vt. 1987).
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Olson v. Townsend, 530 A.2d 566 (Vt. 1987). · cites it 9× “Plaintiff argued below, and the trial court agreed, that defendant was an independent contractor and that the sum owed to him by Rock of Ages did not constitute “earnings” within the meaning of 12 V.S.A. § 3169(b)(1), which states: the term “earnings” means compensation paid or…”
Hueckel v. Hardy (Vt. Super. Ct. 2014). “2(j)(5), the definition of earnings includes commissions, see also 12 V.S.A. § 3169(b)(1). A plaintiff may seek trustee process against a defendant’s future earnings, even if those earnings are not precisely foreseeable at the time of the trustee process hearing.”
— Vt. Stat. Ann. tit. 12, § 3169(b)(1) — 2 cases
Olson v. Townsend, 530 A.2d 566 (Vt. 1987). “Plaintiff argued below, and the trial court agreed, that defendant was an independent contractor and that the sum owed to him by Rock of Ages did not constitute “earnings” within the meaning of 12 V.S.A. § 3169(b)(1), which states: the term “earnings” means compensation paid or…”
Hueckel v. Hardy (Vt. Super. Ct. 2014). “2(j)(5), the definition of earnings includes commissions, see also 12 V.S.A. § 3169(b)(1). A plaintiff may seek trustee process against a defendant’s future earnings, even if those earnings are not precisely foreseeable at the time of the trustee process hearing.”
— Vt. Stat. Ann. tit. 12, § 3169(b)(3) — 1 case
Olson v. Townsend, 530 A.2d 566 (Vt. 1987). “Plaintiff argued below, and the trial court agreed, that defendant was an independent contractor and that the sum owed to him by Rock of Ages did not constitute “earnings” within the meaning of 12 V.S.A. § 3169(b)(1), which states: the term “earnings” means compensation paid or…”
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