Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 395 (2026)

✓ current as of May 2026

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Subchapter 003 : MINIMUM WAGES

(Cite as: 21 V.S.A. § 395)

§ 395. Civil actions

An employee who is paid by an employer less than the applicable wage rate to which the employee is entitled pursuant to this subchapter, shall recover, in a civil action, twice the amount of the minimum wage established pursuant to section 384 of this subchapter less any amount actually paid by the employer, together with costs and reasonable attorney’s fees. An agreement between an employer and an employee to work for less than the wage rates established pursuant to section 384 of this subchapter shall not be a defense to the action. (Amended 2001, No. 47, § 7; 2023, No. 85 (Adj. Sess.), § 92, eff. July 1, 2024.)

Notes of Decisions

Cited in 3 cases (1 in the last 5 years), 1991–2024 · leading case: Lanphear v. Tognelli, 601 A.2d 1384 (Vt. 1991).

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Lanphear v. Tognelli, 601 A.2d 1384 (Vt. 1991). “21 V.S.A. § 395 (“reasonable attorney’s fees .”

Gehlbach v. Gifford Med. Ctr., Inc. (D. Vt. 2024). · cites it 4× “21 V.S.A. § 395 provides a private right of action for violations of § 384: An employee who is paid by an employer less than the applicable wage rate to which the employee is entitled pursuant to this subchapter, shall recover, in a civil action, twice the amount of the minimum…”

United Paperworkers Int'l Union & Its Local 340 v. Specialty Paperboard, Inc., 999 F.2d 51 (2d Cir. 1993). “Vt.Stat. Ann. tit. 21, § 395 (1987 & 1992 Supp.”

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