Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 341 (2026)

✓ current as of May 2026
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Subchapter 002 : WAGES AND MEDIUM OF PAYMENT

(Cite as: 21 V.S.A. § 341)
Notes of Decisions
Cited in 10 cases (6 in the last 5 years), 2001–2026 · leading case: In Re Fedex Ground Package Sys., Inc., Emp. Practices Litig., 662 F. Supp. 2d 1069 (N.D. Ind. 2009).
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In Re Fedex Ground Package Sys., Inc., Emp. Practices Litig., 662 F. Supp. 2d 1069 (N.D. Ind. 2009). · cites it 2× “Vt. Stat. Ann. tit. 21, § 341 . FedEx must prove that (1) the individual has been and will continue to be free from control or direction over the performance of such services, *1113 both under the contract of services and in fact; and (2) the service is either outside all the…”
Baltimore Harbor Charters, Ltd. v. Ayd, 780 A.2d 303 (Md. 2001). “Codified Laws § 60-11-2 (Michie 1993); Vt. Stat. Ann. tit. 21, § 341 (2000); W. Va.”
David Tanzer v. MyWebGrocer, Inc., Richard E. Tarrant, Jr. & Jeremiah F. Tarrant, 203 A.3d 1186 (Vt. 2018). “The trial court granted summary judgment to MyWebGrocer on this claim, concluding that the payment due under the phantom share agreement was uncertain-"more like a lottery ticket than a debt"-and thus did not fall within the definition of wages.”
In re Fedex Ground Package Sys., Inc. Emp. Practices Litig., 273 F.R.D. 516 (N.D. Ind. 2010). · cites it 3× “Vermont The Vermont plaintiffs requested class certification on their claim that FedEx violated the Vermont Independent Contractor Law, Vt. Stat. Ann. tit. 21, §§ 341 , 601(3), and the Vermont Wage Laws, Vt.”
Maynus v. State (Vt. Super. Ct. 2026). · cites it 4× “¶¶ 72– 75; (3) for damages from retaliation by Knight and VNG, presumably under 21 V.S.A. §§ 341– 348 (his amended complaint does not say), id.”
Provencher v. Bimbo Bakeries USA, Inc. (D. Vt. 2023). · cites it 3× “” 21 V.S.A. § 341(5). Bimbo submits that to succeed on their claim for improper wage deductions under Vermont law, Distributors must prove (1) that they were actually employees and (2) that they were paid wages for services rendered.”
Rossetti v. Bare (Vt. Super. Ct. 2025). · cites it 2× “Count 1 set forth claims against Bare only for payment of a contractual bonus for the year 2020 and unpaid PTO; Count 2 founded the same claims on provisions of the Vermont Employment Practices Statute, 21 V.S.A. §§ 341 & 342, and added Defendant Spano; and Count 3 set forth a…”
Gehlbach v. Gifford Med. Ctr., Inc. (D. Vt. 2024). “§ 342, is organized under Chapter 5 “Employment Practices[,]” Subchapter 2 “Wages and Medium of Payment[,]” and states in relevant part: Any employer that is doing business within the State shall pay each week, in lawful money or checks, the wages earned by each employee to a…”
Eastman v. Morrill (Vt. Super. Ct. 2025). “An “employer” is defined as “any person that employes one or more individuals,” and “employee” is defined—subject to certain exceptions—as “an individual who has entered into the employment of an employer.”
Armstrong v. Lane Press (Vt. Super. Ct. 2026). “” 21 V.S.A. § 341(5). In addition, similar to Title VII, under Vermont law, “employer” is defined as “any 2 The Agreement, which was attached to the Complaint, merges into the Complaint and is properly considered in ruling on the motion to dismiss.”
— Vt. Stat. Ann. tit. 21, § 341(1) — 1 case
Maynus v. State (Vt. Super. Ct. 2026). “¶¶ 72– 75; (3) for damages from retaliation by Knight and VNG, presumably under 21 V.S.A. §§ 341– 348 (his amended complaint does not say), id.”
— Vt. Stat. Ann. tit. 21, § 341(2) — 1 case
Maynus v. State (Vt. Super. Ct. 2026). “¶¶ 72– 75; (3) for damages from retaliation by Knight and VNG, presumably under 21 V.S.A. §§ 341– 348 (his amended complaint does not say), id.”
— Vt. Stat. Ann. tit. 21, § 341(5) — 4 cases
Provencher v. Bimbo Bakeries USA, Inc. (D. Vt. 2023). “” 21 V.S.A. § 341(5). Bimbo submits that to succeed on their claim for improper wage deductions under Vermont law, Distributors must prove (1) that they were actually employees and (2) that they were paid wages for services rendered.”
Gehlbach v. Gifford Med. Ctr., Inc. (D. Vt. 2024). “§ 342, is organized under Chapter 5 “Employment Practices[,]” Subchapter 2 “Wages and Medium of Payment[,]” and states in relevant part: Any employer that is doing business within the State shall pay each week, in lawful money or checks, the wages earned by each employee to a…”
Rossetti v. Bare (Vt. Super. Ct. 2025). “Count 1 set forth claims against Bare only for payment of a contractual bonus for the year 2020 and unpaid PTO; Count 2 founded the same claims on provisions of the Vermont Employment Practices Statute, 21 V.S.A. §§ 341 & 342, and added Defendant Spano; and Count 3 set forth a…”
Armstrong v. Lane Press (Vt. Super. Ct. 2026). “” 21 V.S.A. § 341(5). In addition, similar to Title VII, under Vermont law, “employer” is defined as “any 2 The Agreement, which was attached to the Complaint, merges into the Complaint and is properly considered in ruling on the motion to dismiss.”
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