Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 644 (2026)

✓ current as of May 2026

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(Cite as: 21 V.S.A. § 644)

§ 644. Permanent total disability

(a) In case of the following injuries, the disability caused thereby shall be deemed total and permanent:

(1) the total and permanent loss of sight in both eyes;

(2) the loss of both feet at or above the ankle;

(3) the loss of both hands at or above the wrist;

(4) the loss of one hand and one foot;

(5) an injury to the spine resulting in permanent and complete paralysis of both legs or both arms or of one leg and of one arm; and

(6) an injury to the skull resulting in severe traumatic brain injury causing permanent and severe cognitive, physical, or psychiatric disabilities.

(b) The enumeration in subsection (a) of this section is not exclusive, and, in order to determine disability under this section, the Commissioner shall consider other specific characteristics of the claimant, including the claimant’s age, experience, training, education, and mental capacity. (Amended 1977, No. 182 (Adj. Sess.), § 10, eff. May 3, 1978; 1999, No. 97 (Adj. Sess.), § 3; 2013, No. 96 (Adj. Sess.), § 137.)

Notes of Decisions

Cited in 5 cases (1 in the last 5 years), 1982–2021 · 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 8× “Because the claimant’s condition has reached an “end result,” claims for benefits are then treated under the permanent disability sections, 21 V.S.A. §§ 644, 648. See Orvis v. Hutchins, supra, 123 Vt.”

John West v. North Branch Fire Dist. 1, 2021 VT 44 (Vt. 2021). “Claimant John West appeals a decision of the Commissioner of the Vermont Department of Labor concluding that the 2014 amendment to 21 V.S.A. § 644(a)(6) does not apply retroactively.”

Fleury v. Kessel/Duff Constr. Co., 533 A.2d 1197 (Vt. 1987). · cites it 4× “” The Commissioner found the claimant to be permanently totally disabled pursuant to 21 V.S.A. § 644. While that section does not specifically include impairments like those suffered by claimant within the list of injuries that are deemed to cause “total and permanent…”

Montgomery v. Brinver Corp., 457 A.2d 644 (Vt. 1983). “§ 643 (“Period of payments”): Payments shall not continue after such disability ends, nor longer than three hundred and thirty weeks. . . . As this case concerns only temporary total disability benefits, we need not consider the law regarding permanent disability benefits.”

Wroten v. Lamphere, 523 A.2d 1236 (Vt. 1987). “2d at 474 ; see 21 V.S.A. §§ 644, 648. In this case, claimant’s healing period ended on November 29, 1982, and the Commissioner correctly applied the holding of Orvis in terminating temporary benefits on that date.”

— Vt. Stat. Ann. tit. 21, § 644(a)(2) — 1 case

Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982). “Because the claimant’s condition has reached an “end result,” claims for benefits are then treated under the permanent disability sections, 21 V.S.A. §§ 644, 648. See Orvis v. Hutchins, supra, 123 Vt.”

— Vt. Stat. Ann. tit. 21, § 644(a)(6) — 2 cases

John West v. North Branch Fire Dist. 1, 2021 VT 44 (Vt. 2021). “Claimant John West appeals a decision of the Commissioner of the Vermont Department of Labor concluding that the 2014 amendment to 21 V.S.A. § 644(a)(6) does not apply retroactively.”

Fleury v. Kessel/Duff Constr. Co., 533 A.2d 1197 (Vt. 1987). “” The Commissioner found the claimant to be permanently totally disabled pursuant to 21 V.S.A. § 644. While that section does not specifically include impairments like those suffered by claimant within the list of injuries that are deemed to cause “total and permanent…”

— Vt. Stat. Ann. tit. 21, § 644(b) — 2 cases

Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982). “Because the claimant’s condition has reached an “end result,” claims for benefits are then treated under the permanent disability sections, 21 V.S.A. §§ 644, 648. See Orvis v. Hutchins, supra, 123 Vt.”

Fleury v. Kessel/Duff Constr. Co., 533 A.2d 1197 (Vt. 1987). “” The Commissioner found the claimant to be permanently totally disabled pursuant to 21 V.S.A. § 644. While that section does not specifically include impairments like those suffered by claimant within the list of injuries that are deemed to cause “total and permanent…”

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