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Vermont Statutes Annotated

Vt. Stat. Ann. tit. 12, § 3170 (2026)

✓ current as of May 2026
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Subchapter 003 : PARTICULAR PROCEEDINGS

(Cite as: 12 V.S.A. § 3170)
Notes of Decisions
Cited in 7 cases (2 in the last 5 years), 1987–2025 · 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 5× “The Vermont Legislature could have extended the exemptions in 12 V.S.A. § 3170 to all individuals working for compensation, including independent contractors.”
Riendeau v. Canney (In Re Riendeau), 293 B.R. 832 (D. Vt. 2002). · cites it 2× “After receiving the two checks, the Debtor amended his Schedule C to list them, pursuant to Vt. Stat. Ann. tit. 12, § 3170 (b)(1) (Lexis Supp.”
dept labor v. greene (Vt. Super. Ct. 2024). “§ 2740; 12 V.S.A. § 3170; 27 V.S.A. § 101. It is typically the defendant’s burden to show that they are entitled to an exemption.”
Welch v. Lyford (Vt. Super. Ct. 2025). “12 V.S.A. § 3170. Given that there has been a judgment, but no order to pay or post-judgment process, the Small Claims Court’s determination was not binding, and it is not relevant to whether the underlying judgment is allowed.”
Derek Allen & Melinda Allen v. James Moorcroft (Vt. 2012). “The latter claim misapprehends the nature of the exemption for 75% of earnings pursuant to 12 V.S.A. § 3170. This exemption applies to “earnings,” not to funds held by a debtor that derived from wages.”
Riendeau v. Canney, 336 F.3d 78 (2d Cir. 2003). “Riendeau claims that this post-petition income is exempt from the bankruptcy estate under 12 Vt. Stat. Ann. tit. 12, § 3170 (b). The United States District Court for the District of Vermont (William K.”
Riendeau v. Canney, 336 F.3d 78 (2d Cir. 2003). “Riendeau claims that this post-petition income is exempt from the bankruptcy estate under 12 Vt. Stat. Ann. tit. 12, § 3170 (b). The United States District Court for the District of Vermont (William K.”
— Vt. Stat. Ann. tit. 12, § 3170(b)(1) — 1 case
Olson v. Townsend, 530 A.2d 566 (Vt. 1987). “The Vermont Legislature could have extended the exemptions in 12 V.S.A. § 3170 to all individuals working for compensation, including independent contractors.”
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