Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 622 (2026)

✓ current as of May 2026
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(Cite as: 21 V.S.A. § 622)
Notes of Decisions
Cited in 68 cases (10 in the last 5 years), 1973–2026 · leading case: Gallipo v. City of Rutland, 789 A.2d 942 (Vt. 2001).
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Gallipo v. City of Rutland, 789 A.2d 942 (Vt. 2001). · cites it 6× “*225 §§ 49 fMt96 (VFEPA), is not barred by the Workers’ Compensation Act’s (WCA) exclusivity provision, 21 V.S.A. § 622; and (2) the Chief ..may be held personally liable under VFEPA because the municipal officer immunities law, 24 V.”
Wolfe v. Yudichak, 571 A.2d 592 (Vt. 1990). · cites it 12× “See 21 V.S.A. § 622. Because we find that plaintiff is not entitled to workers' compensation benefits, we reverse.”
Colwell v. Allstate Ins., 2003 VT 5 (Vt. 2003). · cites it 3× “In the Bonanno case, we conclude that self insurers must provide UIM coverage, and that 21 V.S.A. § 622, the exclusivity provision of Vermont’s workers’ compensation statute, does not bar the employee from seeking UIM benefits from his self-insured employer.”
Wentworth v. Crawford & Co., 807 A.2d 351 (Vt. 2002). · cites it 3× “See 21 V.S.A § 622. It reasoned that Crawford was hired by her employer after her compensable back injury, and therefore Wentworth’s remedies lie exclusively under the Act pursuant to 21 V.”
Derosia v. Book Press, Inc., 531 A.2d 905 (Vt. 1987). · cites it 5× “Liberty’s argument raises issues of first impression in this jurisdiction requiring us to interpret both the exclusive remedy provision, 21 V.S.A. § 622, and the dual liability provision, 21 V.”
Derosia v. Duro Metal Prods. Co., 519 A.2d 601 (Vt. 1986). · cites it 8× “5(a): Does 21 V.S.A. Section 622 bar an action by an employee, who is entitled to workmen's compensation under 21 V.”
Welch v. Home Two, Inc., 783 A.2d 419 (Vt. 2000). · cites it 6× “was Norman Welch's statutory employer within the meaning of the Workers' Compensation Act, 21 V.S.A. §§ 622, 624 (the Act), and that plaintiffs' common law claims are therefore barred under the employer-immunity of the Act.”
Libercent v. Aldrich, 539 A.2d 981 (Vt. 1987). · cites it 3× “On December 19, 1983, defendants filed a motion to dismiss and for summary judgment on two grounds: first, that the workers’ compensation benefits were his exclusive remedy under 21 V.S.A. § 622, and, second, that the action was barred by the doctrine of sovereign immunity.”
Smith v. Desautels, 2008 VT 17 (Vt. 2008). · cites it 2× “21 V.S.A. § 622. Furthermore, at least initially, the worker has no way of knowing that an employer has failed to comply with its obligation to secure compensation through insurance or other means.”
Stamp Tech, Inc. v. Lydall/Thermal Acoustical, Inc., 2009 VT 91 (Vt. 2009). · cites it 2× “Finally, nothing in the record suggests that plaintiff attempted to "game the system" by waiting to introduce Barroso's deposition until after summary judgment had been entered against it.”
Lydy v. Trustaff, Inc./Wausau Ins. Co., 2013 VT 44 (Vt. 2013). · cites it 2× “Vermont’s workers’ compensation law reflects a trade-off pursuant to which injured workers forfeit their common-law right to sue employers for negligence and the damages associated therewith, but are entitled to a remedy for work injuries independent of fault; employers, on the…”
Catherine Lyons v. Chittenden Cent. Supervisory Union, 185 A.3d 551 (Vt. 2018). · cites it 2× “The plurality’s employment determination may serve to benefit claimant in this instance but work a profound hardship on the next injured student teacher by barring a tort claim against the school district due to the exclusive remedy provision of the Workers’ Compensation Act, 21…”
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