Vt. Stat. Ann. » Title 21 Chapter 9
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 618 (2026)

✓ current as of May 2026
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(Cite as: 21 V.S.A. § 618)
Notes of Decisions
Cited in 50 cases (5 in the last 5 years), 1962–2026 · leading case: Smith v. Desautels, 2008 VT 17 (Vt. 2008).
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Smith v. Desautels, 2008 VT 17 (Vt. 2008). · cites it 12× “In the absence of a waiver that complied with § 618(d), plaintiff never made a binding election that precluded his right to bring this action.”
Joseph L. LeClair v. Hector LeClair, 169 A.3d 743 (Vt. 2017). · cites it 5× “S.A. § 1036. See id. § 618(b)(1), (2), (3).”
Cyr v. Mcdermott's, Inc., 2010 VT 19 (Vt. 2010). · cites it 8× “Having addressed as much of this issue as we are able on the record before us, we further conclude as a matter of law that under the facts of this case § 649 is not a bar to claimant's recovery.”
Gallipo v. City of Rutland, 789 A.2d 942 (Vt. 2001). · cites it 4× “” See 21 V.S.A § 618 (to be eligible for compensation, employee must receive “a personal injury by accident arising out of and in the course of employment”).”
YUSTIN v. Dep't of Pub. Saf., 2011 VT 20 (Vt. 2011). · cites it 8× “We conclude, however, that an employer's credit to itself for sick leave payments paid on account for what was ultimately determined to be a work-related injury, accompanied by a credit to the employee of the sick leave benefits claimed, is entirely consistent with the…”
Clodgo v. Rentavision, Inc., 701 A.2d 1044 (Vt. 1997). · cites it 4× “" 21 V.S.A. § 618. Although only work-related injuries are compensable, we recognize that "even [employees] of maturer years [will] indulge in a moment's diversion from work to joke with or play a prank upon a fellow [employee].”
Catherine Lyons v. Chittenden Cent. Supervisory Union, 185 A.3d 551 (Vt. 2018). · cites it 3× “See 21 V.S.A. §§ 618(a)(1), 622. The statute defines a “worker” or “employee” as “an individual who has entered into the employment of, or works under contract of service or apprenticeship with, an employer.”
Crosby v. City of Burlington, 2003 VT 107 (Vt. 2003). · cites it 5× “Rather, the City would have us hold that such claims are prohibited based on a 1913 constitutional amendment that was added to the Vermont Constitution to assure the survival of the workers' compensation statute, not to restrict its reach.”
Brown v. W.T. Martin Plumbing & Heating, Inc., 2013 VT 38 (Vt. 2013). · cites it 2× “” 21 V.S.A. § 618. Among the benefits potentially available to an injured worker are medical benefits, id .”
Bedini v. Frost, 678 A.2d 893 (Vt. 1996). · cites it 3× “" 21 V.S.A. § 618. By adopting *898 the "unusual stress" standard for stress claims, the Commissioner has determined that some injuries that "aris[e] out of and in the course of .”
Wolfe v. Yudichak, 571 A.2d 592 (Vt. 1990). · cites it 2× “Thus, he is entitled to compensation under 21 V.S.A. § 618 and is barred from other remedies by 21 V.”
Butler v. Huttig Bldg. Prods., 2003 VT 48 (Vt. 2003). · cites it 2× “21 V.S.A. § 618. The Act requires employers to provide the injured worker with medical, temporary and permanent disability, and in certain cases, vocational rehabilitation benefits.”
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— Vt. Stat. Ann. tit. 21, § 618(a) — 2 cases
Mead v. W. Slate, Inc., 2004 VT 11 (Vt. 2004).
Grather v. Gables Inn, Ltd., 751 A.2d 762 (Vt. 2000).
— Vt. Stat. Ann. tit. 21, § 618(a)(1) — 14 cases
Cyr v. Mcdermott's, Inc., 2010 VT 19 (Vt. 2010). “Having addressed as much of this issue as we are able on the record before us, we further conclude as a matter of law that under the facts of this case § 649 is not a bar to claimant's recovery.”
Catherine Lyons v. Chittenden Cent. Supervisory Union, 185 A.3d 551 (Vt. 2018). “See 21 V.S.A. §§ 618(a)(1), 622. The statute defines a “worker” or “employee” as “an individual who has entered into the employment of, or works under contract of service or apprenticeship with, an employer.”
YUSTIN v. Dep't of Pub. Saf., 2011 VT 20 (Vt. 2011). “We conclude, however, that an employer's credit to itself for sick leave payments paid on account for what was ultimately determined to be a work-related injury, accompanied by a credit to the employee of the sick leave benefits claimed, is entirely consistent with the…”
Crosby v. City of Burlington, 2003 VT 107 (Vt. 2003). “Rather, the City would have us hold that such claims are prohibited based on a 1913 constitutional amendment that was added to the Vermont Constitution to assure the survival of the workers' compensation statute, not to restrict its reach.”
Brown v. W.T. Martin Plumbing & Heating, Inc., 2013 VT 38 (Vt. 2013). “” 21 V.S.A. § 618. Among the benefits potentially available to an injured worker are medical benefits, id .”
— Vt. Stat. Ann. tit. 21, § 618(b) — 8 cases
Joseph L. LeClair v. Hector LeClair, 169 A.3d 743 (Vt. 2017). “S.A. § 1036. See id. § 618(b)(1), (2), (3).”
Smith v. Desautels, 2008 VT 17 (Vt. 2008). “In the absence of a waiver that complied with § 618(d), plaintiff never made a binding election that precluded his right to bring this action.”
Smedberg v. Detlef's Custodial Serv., Inc., 2007 VT 99 (Vt. 2007).
Frazier v. Preferred Operators, Inc., 2004 VT 95 (Vt. 2004).
Williams v. United States (D. Vt. 2024).
— Vt. Stat. Ann. tit. 21, § 618(d) — 2 cases
Smith v. Desautels, 2008 VT 17 (Vt. 2008). “In the absence of a waiver that complied with § 618(d), plaintiff never made a binding election that precluded his right to bring this action.”
Williams v. United States (D. Vt. 2024).
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