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

Vt. Stat. Ann. tit. 21, § 650 (2026)

✓ current as of May 2026
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(Cite as: 21 V.S.A. § 650)
Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1964–2025 · leading case: Lydy v. Trustaff, Inc./Wausau Ins. Co., 2013 VT 44 (Vt. 2013).
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Lydy v. Trustaff, Inc./Wausau Ins. Co., 2013 VT 44 (Vt. 2013). · cites it 9× “See 21 V.S.A. § 650. When calculating claimant’s average weekly wage pursuant to § 650, defendant did not include the employer-paid health insurance premiums paid by claimant’s new employer.”
Morin v. Essex Optical/The Hartford, 2005 VT 15 (Vt. 2005). · cites it 6× “The Commissioner found that cost of living increases to permanent total disability benefits under 21 V.S.A. § 650(d) were not available if the resulting benefit amount’ would be greater than claimant’s average weekly wage at the time of her injury, and, on this basis, denied…”
Wolfe v. Yudichak, 571 A.2d 592 (Vt. 1990). · cites it 4× “" 21 V.S.A. § 650(a). It also provides that in instances where "it is impracticable" to compute the employee's rate of remuneration, compensation can be based on the earnings of other persons employed in the same work by the employer or "by a person in the same grade employed in…”
Catherine Lyons v. Chittenden Cent. Supervisory Union, 185 A.3d 551 (Vt. 2018). · cites it 2× “” This is consistent with 21 V.S.A. § 650(a), which provides alternative methods of determining “average weekly wages” on which compensation amounts are calculated where the worker has been employed for only a short time or because of the terms of employment “it is impractical…”
Kimberly Haller v. Champlain Coll., 177 A.3d 497 (Vt. 2017). · cites it 2× “21 V.S.A. § 650. Wages are defined by the Act to include “bonuses and the market value of board, lodging, fuel, and other advantages which can be estimated in money and which the employee receives from the employer as a part of his or her remuneration.”
Quinn v. Pate, 197 A.2d 795 (Vt. 1964). · cites it 3× “However, the appellant contends that by statutory construction the legislative intent evidenced in the act is to allow an aggregation of wages received in both employments in establishing his average weekly earnings under 21 V.S.A. §650. “Average weekly wages shall be computed…”
Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982). “00 for the purpose of vocational rehabilitation? (5) Was there an overpayment of temporary disability benefits pursuant to 21 V.S.A. § 650(d) ? We answer questions one, three, and five in the affirmative, and two, two (a), and four in the negative, for reasons which will be…”
Ehren Hill v. Agri-Mark, Inc., 2025 VT 3 (Vt. 2025). · cites it 9× “Vermont’s Workers’ Compensation Act (WCA) at 21 V.S.A. § 650(a)2 explains how the Department is to compute average weekly wages: (a)(1) Average weekly wages shall be computed in such manner as is best calculated to give the average weekly earnings of the worker during the 26…”
Sanz v. Douglas Collins Constr., 2006 VT 102 (Vt. 2006). “Employer argues that the statute contains no reduction for present value, which would require it to pay more in benefits overall, resulting in a windfall to claimant.”
Sanchez v. Potomac Abatement, Inc., 8 A.3d 737 (Md. 2010). “§ 34A-2-409, 2-412 (2005); Vt. Stat. Ann. tit. 21 § 650(d) (2009); Va.”
Laumann v. Dep't of Pub. Saf., 2004 VT 60 (Vt. 2004). · cites it 2× “See 21 V.S.A. § 650(a) (“Average weekly wages shall be computed in such manner as is best calculated to give the average weekly earnings of the worker during the twelve weeks preceding an injury .”
Hotaling v. St. Johnsbury Trucking Co., 572 A.2d 1351 (Vt. 1990). “21 V.S.A. § 650(a). The Commissioner concluded that there was no evidence that claimant’s trash-hauling business was an in *586 sured employer or a self-insurer, and St.”
Show all 14 citing cases →
— Vt. Stat. Ann. tit. 21, § 650(a) — 7 cases
Wolfe v. Yudichak, 571 A.2d 592 (Vt. 1990). “" 21 V.S.A. § 650(a). It also provides that in instances where "it is impracticable" to compute the employee's rate of remuneration, compensation can be based on the earnings of other persons employed in the same work by the employer or "by a person in the same grade employed in…”
Catherine Lyons v. Chittenden Cent. Supervisory Union, 185 A.3d 551 (Vt. 2018). “” This is consistent with 21 V.S.A. § 650(a), which provides alternative methods of determining “average weekly wages” on which compensation amounts are calculated where the worker has been employed for only a short time or because of the terms of employment “it is impractical…”
Lydy v. Trustaff, Inc./Wausau Ins. Co., 2013 VT 44 (Vt. 2013). “See 21 V.S.A. § 650. When calculating claimant’s average weekly wage pursuant to § 650, defendant did not include the employer-paid health insurance premiums paid by claimant’s new employer.”
Ehren Hill v. Agri-Mark, Inc., 2025 VT 3 (Vt. 2025). “Vermont’s Workers’ Compensation Act (WCA) at 21 V.S.A. § 650(a)2 explains how the Department is to compute average weekly wages: (a)(1) Average weekly wages shall be computed in such manner as is best calculated to give the average weekly earnings of the worker during the 26…”
Laumann v. Dep't of Pub. Saf., 2004 VT 60 (Vt. 2004). “See 21 V.S.A. § 650(a) (“Average weekly wages shall be computed in such manner as is best calculated to give the average weekly earnings of the worker during the twelve weeks preceding an injury .”
— Vt. Stat. Ann. tit. 21, § 650(a)(1) — 1 case
Ehren Hill v. Agri-Mark, Inc., 2025 VT 3 (Vt. 2025). “Vermont’s Workers’ Compensation Act (WCA) at 21 V.S.A. § 650(a)2 explains how the Department is to compute average weekly wages: (a)(1) Average weekly wages shall be computed in such manner as is best calculated to give the average weekly earnings of the worker during the 26…”
— Vt. Stat. Ann. tit. 21, § 650(a)(4) — 1 case
Ehren Hill v. Agri-Mark, Inc., 2025 VT 3 (Vt. 2025). “Vermont’s Workers’ Compensation Act (WCA) at 21 V.S.A. § 650(a)2 explains how the Department is to compute average weekly wages: (a)(1) Average weekly wages shall be computed in such manner as is best calculated to give the average weekly earnings of the worker during the 26…”
— Vt. Stat. Ann. tit. 21, § 650(c) — 2 cases
Lydy v. Trustaff, Inc./Wausau Ins. Co., 2013 VT 44 (Vt. 2013). “See 21 V.S.A. § 650. When calculating claimant’s average weekly wage pursuant to § 650, defendant did not include the employer-paid health insurance premiums paid by claimant’s new employer.”
Lydia Diamond v. Burlington Free Press, 178 A.3d 335 (Vt. 2017).
— Vt. Stat. Ann. tit. 21, § 650(d) — 5 cases
Morin v. Essex Optical/The Hartford, 2005 VT 15 (Vt. 2005). “The Commissioner found that cost of living increases to permanent total disability benefits under 21 V.S.A. § 650(d) were not available if the resulting benefit amount’ would be greater than claimant’s average weekly wage at the time of her injury, and, on this basis, denied…”
Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982). “00 for the purpose of vocational rehabilitation? (5) Was there an overpayment of temporary disability benefits pursuant to 21 V.S.A. § 650(d) ? We answer questions one, three, and five in the affirmative, and two, two (a), and four in the negative, for reasons which will be…”
Sanz v. Douglas Collins Constr., 2006 VT 102 (Vt. 2006). “Employer argues that the statute contains no reduction for present value, which would require it to pay more in benefits overall, resulting in a windfall to claimant.”
Sanchez v. Potomac Abatement, Inc., 8 A.3d 737 (Md. 2010). “§ 34A-2-409, 2-412 (2005); Vt. Stat. Ann. tit. 21 § 650(d) (2009); Va.”
Laumann v. Dep't of Pub. Saf., 2004 VT 60 (Vt. 2004). “See 21 V.S.A. § 650(a) (“Average weekly wages shall be computed in such manner as is best calculated to give the average weekly earnings of the worker during the twelve weeks preceding an injury .”
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