Vermont Statutes Annotated
Vt. Stat. Ann. tit. 12, § 520 (2026)
Payment of wages
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Subchapter 002 : ACTIONS LIMITED
(Cite as: 12 V.S.A. § 520)-
§ 520. Payment of wages
Actions brought on a violation of 21 V.S.A. § 342 shall be brought within two years after the cause of action accrues, and not after. (Added 1977, No. 244 (Adj. Sess.), § 1, eff. May 1, 1978.)
Notes of Decisions
Cited in 5
cases (4 in the last 5 years), 2001–2026 · leading case: Mattson v. Farrell Distrib. Corp., 163 F. Supp. 2d 411 (D. Vt. 2001).
Mattson v. Farrell Distrib. Corp., 163 F. Supp. 2d 411 (D. Vt. 2001). “In the alternative, Farrell urged the Court to apply Vermont’s three-year statute of limitations for lawsuits for personal injury or property damage, Vt.Stat.Ann. tit. 12, § 512(4) and (5). Third, Farrell argued that the Court should apply a three-year-and-ninety-day limitations…”
bockus v. maple pro, No. 21-cv-2243 (Vt. Super. Ct. Feb. 1, 2024). “See 12 V.S.A. § 520 (claims for unpaid wages must be brought within two years of accrual).”
In re dissolution of koffee kup, No. 21-cv-1917 (Vt. Super. Ct. June 5, 2024). “Vermont law sets a two-year limitation on claims for failure to pay wages pursuant Entry Regarding Motion Page 2 of 7 21-CV-01917 In Re: Corporate Dissolution of Koffee Kup Bakery, Inc.”
Gehlbach v. Gifford Med. Ctr., Inc., No. 2:23-cv-00066 (D. Vt. Sept. 6, 2024). “A § 347, entitled “Forfeiture[,]” provides: An employer who violates section 342 or 343 of this title shall forfeit to the individual injured twice the value thereof, to be recovered in a civil action, and all costs and reasonable attorney’s fees.”
Gensoli, No. 2:25-cv-00829 (D. Vt. May 15, 2026). “§ 342 and 12 V.S.A. § 520. (Doc. 596 at 23.) Mr. Gensoli disagrees, relying on a recent decision in the District of Vermont making clear that overtime claims brought under 21 V.”
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