Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 231 (2026)

Employee rights

✓ current as of May 2026
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Subchapter 005 : OCCUPATIONAL SAFETY AND HEALTH

(Cite as: 21 V.S.A. § 231)
Notes of Decisions
Cited in 7 cases (2 in the last 5 years), 1999–2025 · leading case: Haverly v. Kaytec, Inc., 738 A.2d 86 (Vt. 1999).
Haverly v. Kaytec, Inc., 738 A.2d 86 (Vt. 1999). · cites it 14× “Plaintiff pleaded two claims for recovery: (1) Kaytec violated 21 V.S.A. § 231 by discriminating and retaliating against him for complaining about work place health and safety regulations, and (2) Kaytec negligently failed to prevent its employees from violating 21 V.”
Mellin v. Flood Brook Union Sch. Dist., 790 A.2d 408 (Vt. 2001). “§ 495(a)(1); (2) retaliation for requesting accommodations for her disability and filing complaints under the Vermont Occupational Health and Safety Act, 21 V.S.A. § 231 and Vermont Workers’ Compensation Act, 21 V.”
Cole v. Foxmar Inc., 387 F. Supp. 3d 370 (D. Vt. 2019). “VOSHA includes the following provision regarding retaliation: No person shall discharge or in any manner discriminate against any employee because such employee has filed any complaint or instituted or caused to be instituted any proceeding under or related to this chapter or…”
Wyatt v. City of Barre, 885 F. Supp. 2d 682 (D. Vt. 2012). · cites it 2× “” Vt. Stat. Ann. tit. 21, § 231 (a). As previously discussed, the Vermont Supreme Court has stated the elements of a VOSHA retaliation claim as (1) the plaintiff was engaged in a protected activity, (2) the defendants knew of that activity, (3) plaintiff suffered an adverse…”
Buksh v. Dr. William Sarchino DPM Foot & Ankle Surgeon (D. Vt. 2022). · cites it 3× “§201 for failing to provide “safe and healthful working conditions” and retaliation following Plaintiffs’ complaints in violation of 21 V.S.A. §231 by Dr. Sarchino, SVMC, and SVHC; (6) a violation of the standard of ordinary care against Dr.”
Chandler v. Long Falls Paperboard, LLC (D. Vt. 2025). “21 V.S.A. § 231(a). “Although VOSHA is ‘patterned after the federal [Occupational Safety and Health Act (“OSHA”),|’ VOSHA provides for a private right of action for any aggrieved employee who has a claim for retaliation under the statute, while OSHA does not.”
Worthen v. Gaulin (Vt. Super. Ct. 2005). “21 V.S.A. §§ 231–232. This statutory right of action provides for such relief as “reinstatement, triple wages, damages, costs and reasonable attorney’s fees”—certainly far beyond relief available at common law through a wrongful discharge action.”
— Vt. Stat. Ann. tit. 21, § 231(a) — 3 cases
Haverly v. Kaytec, Inc., 738 A.2d 86 (Vt. 1999). “Plaintiff pleaded two claims for recovery: (1) Kaytec violated 21 V.S.A. § 231 by discriminating and retaliating against him for complaining about work place health and safety regulations, and (2) Kaytec negligently failed to prevent its employees from violating 21 V.”
Cole v. Foxmar Inc., 387 F. Supp. 3d 370 (D. Vt. 2019). “VOSHA includes the following provision regarding retaliation: No person shall discharge or in any manner discriminate against any employee because such employee has filed any complaint or instituted or caused to be instituted any proceeding under or related to this chapter or…”
Chandler v. Long Falls Paperboard, LLC (D. Vt. 2025). “21 V.S.A. § 231(a). “Although VOSHA is ‘patterned after the federal [Occupational Safety and Health Act (“OSHA”),|’ VOSHA provides for a private right of action for any aggrieved employee who has a claim for retaliation under the statute, while OSHA does not.”
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.