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

Vt. Stat. Ann. tit. 21, § 624 (2026)

✓ current as of May 2026
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(Cite as: 21 V.S.A. § 624)
Notes of Decisions
Cited in 66 cases (5 in the last 5 years), 1966–2026 · leading case: Travelers Ins. v. Henry, 2005 VT 68 (Vt. 2005).
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Travelers Ins. v. Henry, 2005 VT 68 (Vt. 2005). · cites it 18× “Generally speaking, 21 V.S.A. § 624 allows an injured employee to pursue a cause of action against a third party where the injury for which workers’ compensation is payable “was caused under circumstances creating a legal liability to pay the resulting damages in some person…”
Derosia v. Duro Metal Prods. Co., 519 A.2d 601 (Vt. 1986). · cites it 30× “The question as framed must clearly be answered in the affirmative inasmuch as 21 V.S.A. § 622 excludes "all other rights and remedies of such employee .”
The Travelers Ins. Co. v. Susan J. Carpenter, 411 F.3d 323 (2d Cir. 2005). · cites it 5× “We hold that a workers’ compensation insurer’s right to reimbursement under Vt. Stat. Ann. tit. 21, § 624 (e) (2003) of proceeds of an uninsured/underinsured motorist policy is governed by the law in effect at the time that the injured worker recovers those proceeds.”
Chayer v. Ethan Allen, Inc., 2008 VT 45 (Vt. 2008). · cites it 6× “2d 601, 604 (1986) (quoting 21 V.S.A. § 624). We noted, in support of this holding, that “it is not of the essence of the compensation process that the carrier should step out of its fundamental role as financial guarantor and payor and go into the safety inspection service or…”
Smedberg v. Detlef's Custodial Serv., Inc., 2007 VT 99 (Vt. 2007). · cites it 3× “Section 624 allows injured employees to bring personal injury actions against third parties “under circumstances creating a legal liability to pay the resulting damages in some person other than the employer.” Because § 624 allows personal injury actions against third parties…”
Roger Rodrigue & Tealla Rodrigue v. Vincent Illuzzi, 2022 VT 9 (Vt. 2022). · cites it 2× “See 21 V.S.A. § 624 (providing that exclusive- remedy provision in Vermont workers’ compensation act does not preclude common-law claims against coworkers); Libercent v.”
YUSTIN v. Dep't of Pub. Saf., 2011 VT 20 (Vt. 2011). · cites it 6× “§ 618, DPS first paid claimant in the form of sick leave which it later replenished upon accepting the Department's interim ruling that the disability was work-related.”
Libercent v. Aldrich, 539 A.2d 981 (Vt. 1987). · cites it 3× “Whether a state employee who was injured performing his duties as a state employee who received workers’ compensation can maintain an action against a fellow state employee, for acts or omissions in the course of his state employment, pursuant to Title 21 V.S.A. § 624. *78 2.…”
Smith v. Desautels, 2008 VT 17 (Vt. 2008). · cites it 2× “For example, many decisions of this Court have involved work-related negligence actions brought under the dual-liability provisions of 21 V.S.A. § 624. In those cases, the superior court has determined whether §§ 622 and 624(a) allow for civil suits, rather than referring the…”
Lorrain v. Ryan, 628 A.2d 543 (Vt. 1993). · cites it 3× “21 V.S.A. § 624(a). The import of this section is that the exclusivity provision bars the employee’s tort recovery only with respect to claims against the employer.”
Gerrish v. Savard, 739 A.2d 1195 (Vt. 1999). · cites it 3× “While injured workers may bring negligence actions against persons other than the employer, see 21 V.S.A. § 624(a), defendant argued that he was not liable as a co-employee because plaintiff had alleged only failure to maintain a safe work place, which is a nondelegable duty of…”
Travelers Ins. Co. v. John Henry v. Co-Operative Ins. Companies, Third-Party, 470 F.3d 56 (2d Cir. 2006). · cites it 5× “Vt. Stat. Ann. tit. 21, § 624 (e) (2003), amended by 1999 Vt.”
Show all 66 citing cases →
— Vt. Stat. Ann. tit. 21, § 624(a) — 29 cases
Derosia v. Duro Metal Prods. Co., 519 A.2d 601 (Vt. 1986). “The question as framed must clearly be answered in the affirmative inasmuch as 21 V.S.A. § 622 excludes "all other rights and remedies of such employee .”
Gerrish v. Savard, 739 A.2d 1195 (Vt. 1999). “While injured workers may bring negligence actions against persons other than the employer, see 21 V.S.A. § 624(a), defendant argued that he was not liable as a co-employee because plaintiff had alleged only failure to maintain a safe work place, which is a nondelegable duty of…”
Welch v. Home Two, Inc., 783 A.2d 419 (Vt. 2000).
Libercent v. Aldrich, 539 A.2d 981 (Vt. 1987). “Whether a state employee who was injured performing his duties as a state employee who received workers’ compensation can maintain an action against a fellow state employee, for acts or omissions in the course of his state employment, pursuant to Title 21 V.S.A. § 624. *78 2.…”
Roger Rodrigue & Tealla Rodrigue v. Vincent Illuzzi, 2022 VT 9 (Vt. 2022). “See 21 V.S.A. § 624 (providing that exclusive- remedy provision in Vermont workers’ compensation act does not preclude common-law claims against coworkers); Libercent v.”
— Vt. Stat. Ann. tit. 21, § 624(a)(1) — 2 cases
Williams v. United States (D. Vt. 2024).
Dearden v. South Burlington Opco (Vt. Super. Ct. 2026).
— Vt. Stat. Ann. tit. 21, § 624(b) — 1 case
Derosia v. Duro Metal Prods. Co., 519 A.2d 601 (Vt. 1986). “The question as framed must clearly be answered in the affirmative inasmuch as 21 V.S.A. § 622 excludes "all other rights and remedies of such employee .”
— Vt. Stat. Ann. tit. 21, § 624(c) — 1 case
Derosia v. Duro Metal Prods. Co., 519 A.2d 601 (Vt. 1986). “The question as framed must clearly be answered in the affirmative inasmuch as 21 V.S.A. § 622 excludes "all other rights and remedies of such employee .”
— Vt. Stat. Ann. tit. 21, § 624(e) — 18 cases
Travelers Ins. v. Henry, 2005 VT 68 (Vt. 2005). “Generally speaking, 21 V.S.A. § 624 allows an injured employee to pursue a cause of action against a third party where the injury for which workers’ compensation is payable “was caused under circumstances creating a legal liability to pay the resulting damages in some person…”
YUSTIN v. Dep't of Pub. Saf., 2011 VT 20 (Vt. 2011). “§ 618, DPS first paid claimant in the form of sick leave which it later replenished upon accepting the Department's interim ruling that the disability was work-related.”
St. Paul Fire & Marine Ins. v. Surdam, 595 A.2d 264 (Vt. 1991).
Smedberg v. Detlef's Custodial Serv., Inc., 2007 VT 99 (Vt. 2007). “Section 624 allows injured employees to bring personal injury actions against third parties “under circumstances creating a legal liability to pay the resulting damages in some person other than the employer.” Because § 624 allows personal injury actions against third parties…”
Progressive Cas. Ins. Co. v. Est. of Keenan, 2007 VT 86 (Vt. 2007).
— Vt. Stat. Ann. tit. 21, § 624(h) — 2 cases
Chayer v. Ethan Allen, Inc., 2008 VT 45 (Vt. 2008). “2d 601, 604 (1986) (quoting 21 V.S.A. § 624). We noted, in support of this holding, that “it is not of the essence of the compensation process that the carrier should step out of its fundamental role as financial guarantor and payor and go into the safety inspection service or…”
Murphy v. Sentry Ins., 2014 VT 25 (Vt. 2014).
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