Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 345 (2026)

✓ current as of May 2026

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Subchapter 002 : WAGES AND MEDIUM OF PAYMENT

(Cite as: 21 V.S.A. § 345)

§ 345. Nonpayment of wages and benefits

(a) An employer who violates section 342, 343, 482, or 483 of this title shall be fined not more than $5,000.00. If the employer is a corporation, the president or other officers who have control of the payment operations of the corporation shall be considered employers and liable to the employee for actual wages due when the officer has willfully and without good cause participated in knowing violations of this subchapter.

(b) In addition to any other penalty or punishment prescribed by law, any employer who, pursuant to an oral or written employment agreement, is required to provide benefits to an employee shall be liable to the employee for actual damages caused by the failure to pay for the benefits, and where the failure to pay is knowing and willful and continues for 30 days after the payments are due shall be assessed a civil penalty by the Commissioner of not more than $5,000.00.

(c) The Commissioner may enforce collection of the penalties assessed under this section in the Civil Division of the Superior Court. (Amended 1963, No. 188, § 1; 2013, No. 15, § 4; 2015, No. 69 (Adj. Sess.), § 5, eff. Jan. 1, 2017; 2017, No. 74, § 33; 2023, No. 85 (Adj. Sess.), § 82, eff. July 1, 2024.)

Notes of Decisions

Cited in 5 cases (1 in the last 5 years), 1980–2022 · leading case: State v. Carpenter, 412 A.2d 285 (Vt. 1980).

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State v. Carpenter, 412 A.2d 285 (Vt. 1980). · cites it 7× “Indeed, such a rational basis can be articulated to support the different treatment accorded to employers and corporate officers under 21 V.S.A. § 345. The intent of the statute is to foster the regular payment of wages to employees.”

State v. Harty, 518 A.2d 30 (Vt. 1986). “” 21 V.S.A. § 345 provides, in part, that “[e]ach employer who violates sections 342 and 343 .”

Hubacz v. Vill. of Waterbury (Vt. Super. Ct. 2016). · cites it 7× “He also seeks relief for the nonpayment of wages and benefits pursuant to 21 V.S.A. §§ 345, 347 (Counts 2 and 3 of the Complaint), which he believes started accruing at the time of his first termination or had accrued at the time of the federal court’s remand decision.”

Cole v. Foxmar, Inc (D. Vt. 2022). · cites it 2× “” 21 V.S.A. § 345; see also 21 V.S.A. § 483(m) (“An employer who violates [VESTA] shall be subject to the penalty provisions of [21 V.”

Caldwell v. Shover, 428 A.2d 1131 (Vt. 1981). “Violation carries a criminal penalty of a fine or imprisonment or both under 21 V.S.A. § 345. This matter is not concerned with a prosecution under that statute, but is limited to its asserted effect of making the agreement between this employer and employee illegal and…”

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