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

Vt. Stat. Ann. tit. 21, § 641 (2026)

✓ current as of May 2026
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(Cite as: 21 V.S.A. § 641)
Notes of Decisions
Cited in 12 cases, 1982–2017 · leading case: Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982).
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Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982). · cites it 3× “He relies on language in 21 V.S.A. § 641 (b) which provides that an injured worker is “entitled to such vocational rehabilitation services .”
Wentworth v. Crawford & Co., 807 A.2d 351 (Vt. 2002). · cites it 2× “The following month, defendant Crawford & Company, who was hired to provide Wentworth with vocational rehabilitation benefits pursuant to the Workers’ Compensation Act, see 21 V.S.A. § 641(a) (Cum. Supp. 2001), made an initial evaluation of Wentworth, including her physical…”
Debra Morisseau v. Hannaford Bros., 2016 VT 17 (Vt. 2016). “” 21 V.S.A. § 641(a); see also Worker’s Compensation Vocational Rehabilitation Rules, Rule 50, Code of Vt.”
Kimberly Haller v. Champlain Coll., 177 A.3d 497 (Vt. 2017). · cites it 2× “, 21 V.S.A. § 641. Though developments have confused that basic goal, with some states calculating payments by including fringe benefits that were not identified or considered when the law was passed, the majority of jurisdictions judicially or legislatively exclude fringe…”
Gintof v. Husky Injection Molding, 2005 VT 8 (Vt. 2005). · cites it 3× “” 21 V.S.A. § 641(a). The statute further stipulates that “[wjhen vocational rehabilitation requires residence at or near a facility or institution, away from the employee’s customary residence, the reasonable cost of board, lodging, or; travel, or both, shall be paid for by the…”
Wroten v. Lamphere, 523 A.2d 1236 (Vt. 1987). · cites it 3× “The legislature has carefully juxtaposed vocational rehabilitation under 21 V.S.A. § 641 with other benefits available under the statute so that appropriate incentives are maintained.”
King v. Snide, 479 A.2d 752 (Vt. 1984). “Is the plaintiff entitled to vocational rehabilitation benefits under 21 V.S.A. § 641 (b) ? At oral argument, plaintiff conceded that Bemis was not his common law employer and intimated that Snide, his direct employer, had no workers’ compensation insurance coverage at the time…”
Peabody v. Home Ins., 751 A.2d 783 (Vt. 2000). · cites it 2× “On the merits, the crux of the parties’ dispute concerns claimant’s initial burden under 21 VS.A. § 641 to show that “as a result of an injury covered by this chapter, [she] is unable to perform work for which [she] has previous training or experience.”
Lavalley v. E.B. & A.C. Whiting Co., 692 A.2d 367 (Vt. 1997). “[*] Although the majority refers to statutory provisions that mandate rehabilitation services for injured workers, see 21 V.S.A. § 641, defendant's policy of providing light-duty work for some employees and not for others is not based on the workers' compensation laws.”
Norse v. Melsur Corp., 465 A.2d 275 (Vt. 1983). “With regard to the cross-appeal, we affirm the Commissioner’s denial of claimant’s request for vocational rehabilitation benefits under 21 V.S.A. § 641 (b). The Commissioner found the testimony that “claimant was unable to perform work for which he had previous training .”
Stamper v. Univ. Apts., Inc., 522 A.2d 227 (Vt. 1986). “See 21 V.S.A. § 641(b); Bishop, 140 Vt. at 578-79 , 442 A.”
Buote v. Verizon New England, 249 F. Supp. 2d 422 (D. Vt. 2003). “Vt. Stat. Ann. tit. 21, § 641 (a) (Lexis Supp.”
— Vt. Stat. Ann. tit. 21, § 641(a) — 3 cases
Wentworth v. Crawford & Co., 807 A.2d 351 (Vt. 2002). “The following month, defendant Crawford & Company, who was hired to provide Wentworth with vocational rehabilitation benefits pursuant to the Workers’ Compensation Act, see 21 V.S.A. § 641(a) (Cum. Supp. 2001), made an initial evaluation of Wentworth, including her physical…”
Debra Morisseau v. Hannaford Bros., 2016 VT 17 (Vt. 2016). “” 21 V.S.A. § 641(a); see also Worker’s Compensation Vocational Rehabilitation Rules, Rule 50, Code of Vt.”
Gintof v. Husky Injection Molding, 2005 VT 8 (Vt. 2005). “” 21 V.S.A. § 641(a). The statute further stipulates that “[wjhen vocational rehabilitation requires residence at or near a facility or institution, away from the employee’s customary residence, the reasonable cost of board, lodging, or; travel, or both, shall be paid for by the…”
— Vt. Stat. Ann. tit. 21, § 641(b) — 4 cases
Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982). “He relies on language in 21 V.S.A. § 641 (b) which provides that an injured worker is “entitled to such vocational rehabilitation services .”
Wroten v. Lamphere, 523 A.2d 1236 (Vt. 1987). “The legislature has carefully juxtaposed vocational rehabilitation under 21 V.S.A. § 641 with other benefits available under the statute so that appropriate incentives are maintained.”
Peabody v. Home Ins., 751 A.2d 783 (Vt. 2000). “On the merits, the crux of the parties’ dispute concerns claimant’s initial burden under 21 VS.A. § 641 to show that “as a result of an injury covered by this chapter, [she] is unable to perform work for which [she] has previous training or experience.”
Stamper v. Univ. Apts., Inc., 522 A.2d 227 (Vt. 1986). “See 21 V.S.A. § 641(b); Bishop, 140 Vt. at 578-79 , 442 A.”
— Vt. Stat. Ann. tit. 21, § 641(c) — 1 case
Gintof v. Husky Injection Molding, 2005 VT 8 (Vt. 2005). “” 21 V.S.A. § 641(a). The statute further stipulates that “[wjhen vocational rehabilitation requires residence at or near a facility or institution, away from the employee’s customary residence, the reasonable cost of board, lodging, or; travel, or both, shall be paid for by the…”
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