Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 662 (2026)

✓ current as of May 2026
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(Cite as: 21 V.S.A. § 662)
Notes of Decisions
Cited in 20 cases, 1983–2017 · leading case: Travelers Indem. Co. v. Wallis, 2003 VT 103 (Vt. 2003).
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Travelers Indem. Co. v. Wallis, 2003 VT 103 (Vt. 2003). · cites it 7× “In its suit, Travelers sought to challenge certain Department practices in issuing interim orders of benefits under 21 V.S.A. § 662(b), and asserted that the statute is constitutionally deficient on its face.”
YUSTIN v. Dep't of Pub. Saf., 2011 VT 20 (Vt. 2011). · cites it 8× “See 21 V.S.A. § 662(b) (authorizing *612 commissioner to order interim payment of compensation, pending a final determination and subject to repayment, when the parties are not in agreement).”
Gallipo v. City of Rutland, 2005 VT 83 (Vt. 2005). “” 21 V.S.A § 662(b). In this case, when the Commissioner examined defendant’s opposition to paying plaintiff benefits, defendant had not submitted any medical documentation supporting denial and, consequently, the only medical evidence was the report from plaintiff’s doctor.”
Longe v. Boise Cascade Corp., 762 A.2d 1248 (Vt. 2000). · cites it 3× “See 21 V.S.A. § 662(a). Under the agreement, Boise paid claimant temporary total disability (TTD) benefits from *216 November 23, 1984 until claimant returned to work in May 1985, as well as medical expenses related to the 1983 injury.”
The Travelers Ins. Co. v. Susan J. Carpenter, 411 F.3d 323 (2d Cir. 2005). “The case may be distinguishable in that the Commissioner's jurisdiction was also invoked to settle the issue (not present here) of whether the Commissioner's failure to approve of a settlement agreement dividing a UIM recovery voided that agreement under Vt. Stat. Ann. tit. 21,…”
Gallipo v. City of Rutland, 789 A.2d 942 (Vt. 2001). “The department awarded plaintiff interim benefits pursuant to 21 V.S.A. § 662(b) while the adjudication of plaintiffs right to a permanent award was pending.”
Farris v. Bryant Grinder Corp., 2005 VT 5 (Vt. 2005). · cites it 2× “On appeal, Wausau argues that 21 V.S.A. § 662(c) controls and allocates the burden of proof to AIG.”
Montgomery v. Brinver Corp., 457 A.2d 644 (Vt. 1983). “21 V.S.A. § 662. Given that this statutory scheme must be liberally construed, Herbert v.”
Wood v. Fletcher Allen Health Care, 739 A.2d 1201 (Vt. 1999). “The analogy is barely recognizable since claimant’s pregnancy is not a work-related injury, and FAHC is arguing for temporary suspension of benefits rather than an allocation of benefits between employers. We find its argument virtually indistinguishable from its earlier…”
Sanz v. Douglas Collins Constr., 2006 VT 102 (Vt. 2006). “Under the previous statutory scheme and workers’ compensation rules, lump sum payments were allowed only when the parties agreed to lump sum payments in settlements under 21 V.S.A. § 662(a) and when the Commissioner approved such settlements.”
Merriam v. AIG Claims Servs., Inc., 2008 VT 8 (Vt. 2008). “That order, pursuant to 21 V.S.A. § 662(c), ordered defendant to: immediately pay interim benefits.”
Cehic v. MacK Molding, Inc., 2006 VT 12 (Vt. 2006). “2 (noting Commissioner’s ability to fairly define and apportion liability of different employers where different accidents produce distinct injuries and obligation to do so pursuant to 21 V.”
Show all 20 citing cases →
— Vt. Stat. Ann. tit. 21, § 662(a) — 6 cases
Longe v. Boise Cascade Corp., 762 A.2d 1248 (Vt. 2000). “See 21 V.S.A. § 662(a). Under the agreement, Boise paid claimant temporary total disability (TTD) benefits from *216 November 23, 1984 until claimant returned to work in May 1985, as well as medical expenses related to the 1983 injury.”
Sanz v. Douglas Collins Constr., 2006 VT 102 (Vt. 2006). “Under the previous statutory scheme and workers’ compensation rules, lump sum payments were allowed only when the parties agreed to lump sum payments in settlements under 21 V.S.A. § 662(a) and when the Commissioner approved such settlements.”
Marshall v. State, Vermont State Hosp., 124 A.3d 435 (Vt. 2015).
Lydia Diamond v. Burlington Free Press, 178 A.3d 335 (Vt. 2017).
Brandy Clayton v. J.C. Penney Corp., 177 A.3d 522 (Vt. 2017).
— Vt. Stat. Ann. tit. 21, § 662(b) — 6 cases
Travelers Indem. Co. v. Wallis, 2003 VT 103 (Vt. 2003). “In its suit, Travelers sought to challenge certain Department practices in issuing interim orders of benefits under 21 V.S.A. § 662(b), and asserted that the statute is constitutionally deficient on its face.”
YUSTIN v. Dep't of Pub. Saf., 2011 VT 20 (Vt. 2011). “See 21 V.S.A. § 662(b) (authorizing *612 commissioner to order interim payment of compensation, pending a final determination and subject to repayment, when the parties are not in agreement).”
Gallipo v. City of Rutland, 2005 VT 83 (Vt. 2005). “” 21 V.S.A § 662(b). In this case, when the Commissioner examined defendant’s opposition to paying plaintiff benefits, defendant had not submitted any medical documentation supporting denial and, consequently, the only medical evidence was the report from plaintiff’s doctor.”
Gallipo v. City of Rutland, 789 A.2d 942 (Vt. 2001). “The department awarded plaintiff interim benefits pursuant to 21 V.S.A. § 662(b) while the adjudication of plaintiffs right to a permanent award was pending.”
Dodge v. Precision Constr. Prods., Inc., 2003 VT 11 (Vt. 2003).
— Vt. Stat. Ann. tit. 21, § 662(c) — 6 cases
Farris v. Bryant Grinder Corp., 2005 VT 5 (Vt. 2005). “On appeal, Wausau argues that 21 V.S.A. § 662(c) controls and allocates the burden of proof to AIG.”
Wood v. Fletcher Allen Health Care, 739 A.2d 1201 (Vt. 1999). “The analogy is barely recognizable since claimant’s pregnancy is not a work-related injury, and FAHC is arguing for temporary suspension of benefits rather than an allocation of benefits between employers. We find its argument virtually indistinguishable from its earlier…”
Merriam v. AIG Claims Servs., Inc., 2008 VT 8 (Vt. 2008). “That order, pursuant to 21 V.S.A. § 662(c), ordered defendant to: immediately pay interim benefits.”
Cehic v. MacK Molding, Inc., 2006 VT 12 (Vt. 2006). “2 (noting Commissioner’s ability to fairly define and apportion liability of different employers where different accidents produce distinct injuries and obligation to do so pursuant to 21 V.”
Longe v. Boise Cascade Corp., 762 A.2d 1248 (Vt. 2000). “See 21 V.S.A. § 662(a). Under the agreement, Boise paid claimant temporary total disability (TTD) benefits from *216 November 23, 1984 until claimant returned to work in May 1985, as well as medical expenses related to the 1983 injury.”
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