Vt. Stat. Ann. » Title 21 Chapter 5
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 384 (2026)

✓ current as of May 2026
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Subchapter 003 : MINIMUM WAGES

(Cite as: 21 V.S.A. § 384)
Notes of Decisions
Cited in 18 cases (5 in the last 5 years), 1991–2026 · leading case: Paul Flint v. Dep't of Labor, 177 A.3d 1080 (Vt. 2017).
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Paul Flint v. Dep't of Labor, 177 A.3d 1080 (Vt. 2017). · cites it 7× “Employee first argues that he is entitled to overtime pay for hours worked in excess of forty hours per week because-through a 1994 revision to 21 V.S.A. § 384(b)(7) that refers to the federal Fair Labor Standards Act (FLSA)-the Legislature intended to provide state employees…”
Beaulieu v. State of Vermont, 807 F.3d 478 (2d Cir. 2015). · cites it 4× “The complaint asserted that Vermont, by act of its legislature, Vt. Stat. Ann. tit. 21, § 384 (b)(7), had expressly waived its sovereign immunity to private suit under the FLSA.”
Havey v. Homebound Mortg., Inc., 547 F.3d 158 (2d Cir. 2008). “Procedural History Havey brought this action in the District Court, claiming that defendants, Home-bound and its officers, failed to pay her overtime compensation as required by the FLSA and the Vermont Fair Employment Practice Act, 21 V.S.A. § 384(b). In response, defendants…”
Stowell v. Action Moving & Storage, Inc., 933 A.2d 1128 (Vt. 2007). “The Court in Lanphear held that an employee could not recover penalties under § 347 for an employer's failure to pay the minimum wage in accordance with 21 V.S.A. § 384. Id. at 563-64, 601 A.2d at 1386 .”
Lanphear v. Tognelli, 601 A.2d 1384 (Vt. 1991). · cites it 2× “Plaintiff brought suit against defendants, the owners and operators of a small 12-unit motel in Burlington, alleging violation of 21 V.S.A. § 384(a), Vermont’s minimum wage law.”
Banford v. Entergy Nuclear Operations, Inc., 74 F. Supp. 3d 658 (D. Vt. 2015). “The Plaintiffs argue that their overtime claims brought under Vermont law are subject to a six-year statute of limitations pursuant to 21 V.S.A. § 384. Entergy disputes this. A willful violation of the FLSA extends the statute of limitations to three years.”
Gehlbach v. Gifford Med. Ctr., Inc. (D. Vt. 2024). · cites it 13× “Plaintiffs seek a declaratory judgment that 21 V.S.A. § 384 and the applicable six- year statute of limitations in 12 V.”
Stowell v. Action Moving & Storage, Inc., 2007 VT 46 (Vt. 2007). “The Court in Lanphear held that an employee could not recover penalties under § 347 for an employer’s failure to pay the minimum wage in accordance with 21 V.S.A. § 384. Id. at 563-64, 601 A.2d at 1386 .”
Flint v. State of Vermont Dept. of Labor (Vt. Super. Ct. 2016). · cites it 6× “21 V.S.A. § 384. There is no disagreement that Mr.”
Christie Mitchell v. NBT Bank, N.A., 2022 VT 17 (Vt. 2022). “2 The parties agree that because Vermont’s wage-and-maximum-hours law, 21 V.S.A. § 384, is substantially like the FLSA, our conclusion today applies equally to § 384.”
Provencher v. Bimbo Bakeries USA, Inc. (D. Vt. 2023). · cites it 3× “It also mandates that employers pay employees at least one and one-half times the regular wage rate” for each hour worked above 40 in any given week, 21 V.S.A. § 384(b), and specifies that certain payments made to employees “as may be usual in a particular employer- employee…”
Gerald Gensoli v. FedEx Ground Package Sys., Inc. (D. Vt. 2026). · cites it 3× “Gensoli disagrees, relying on a recent decision in the District of Vermont making clear that overtime claims brought under 21 V.S.A. § 384 are subject to a six-year statute of limitations, not a two-year statute of limitations.”
Show all 18 citing cases →
— Vt. Stat. Ann. tit. 21, § 384(a) — 1 case
Lanphear v. Tognelli, 601 A.2d 1384 (Vt. 1991). “Plaintiff brought suit against defendants, the owners and operators of a small 12-unit motel in Burlington, alleging violation of 21 V.S.A. § 384(a), Vermont’s minimum wage law.”
— Vt. Stat. Ann. tit. 21, § 384(b) — 8 cases
Havey v. Homebound Mortg., Inc., 547 F.3d 158 (2d Cir. 2008). “Procedural History Havey brought this action in the District Court, claiming that defendants, Home-bound and its officers, failed to pay her overtime compensation as required by the FLSA and the Vermont Fair Employment Practice Act, 21 V.S.A. § 384(b). In response, defendants…”
Eric Gracie v. Dep't of Labor (George Wohlgemuth Landscape, Emp.) (Vt. 2017).
Gehlbach v. Gifford Med. Ctr., Inc. (D. Vt. 2024). “Plaintiffs seek a declaratory judgment that 21 V.S.A. § 384 and the applicable six- year statute of limitations in 12 V.”
Provencher v. Bimbo Bakeries USA, Inc. (D. Vt. 2023). “It also mandates that employers pay employees at least one and one-half times the regular wage rate” for each hour worked above 40 in any given week, 21 V.S.A. § 384(b), and specifies that certain payments made to employees “as may be usual in a particular employer- employee…”
Gerald Gensoli v. FedEx Ground Package Sys., Inc. (D. Vt. 2026). “Gensoli disagrees, relying on a recent decision in the District of Vermont making clear that overtime claims brought under 21 V.S.A. § 384 are subject to a six-year statute of limitations, not a two-year statute of limitations.”
— Vt. Stat. Ann. tit. 21, § 384(b)(4) — 1 case
Gehlbach v. Gifford Med. Ctr., Inc. (D. Vt. 2024). “Plaintiffs seek a declaratory judgment that 21 V.S.A. § 384 and the applicable six- year statute of limitations in 12 V.”
— Vt. Stat. Ann. tit. 21, § 384(b)(5) — 1 case
Gerald Gensoli v. FedEx Ground Package Sys., Inc. (D. Vt. 2026). “Gensoli disagrees, relying on a recent decision in the District of Vermont making clear that overtime claims brought under 21 V.S.A. § 384 are subject to a six-year statute of limitations, not a two-year statute of limitations.”
— Vt. Stat. Ann. tit. 21, § 384(b)(7) — 2 cases
Paul Flint v. Dep't of Labor, 177 A.3d 1080 (Vt. 2017). “Employee first argues that he is entitled to overtime pay for hours worked in excess of forty hours per week because-through a 1994 revision to 21 V.S.A. § 384(b)(7) that refers to the federal Fair Labor Standards Act (FLSA)-the Legislature intended to provide state employees…”
Flint v. State of Vermont Dept. of Labor (Vt. Super. Ct. 2016). “21 V.S.A. § 384. There is no disagreement that Mr.”
— Vt. Stat. Ann. tit. 21, § 384(c) — 3 cases
Lanphear v. Tognelli, 601 A.2d 1384 (Vt. 1991). “Plaintiff brought suit against defendants, the owners and operators of a small 12-unit motel in Burlington, alleging violation of 21 V.S.A. § 384(a), Vermont’s minimum wage law.”
Provencher v. Bimbo Bakeries USA, Inc. (D. Vt. 2023). “It also mandates that employers pay employees at least one and one-half times the regular wage rate” for each hour worked above 40 in any given week, 21 V.S.A. § 384(b), and specifies that certain payments made to employees “as may be usual in a particular employer- employee…”
Gehlbach v. Gifford Med. Ctr., Inc. (D. Vt. 2024). “Plaintiffs seek a declaratory judgment that 21 V.S.A. § 384 and the applicable six- year statute of limitations in 12 V.”
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