Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 664 (2026)

✓ current as of May 2026

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(Cite as: 21 V.S.A. § 664)

§ 664. Trial and award

Within 60 days after a hearing is held, the Commissioner shall make an award supported by findings of fact and the applicable law and shall send a copy of the award to the parties. If the employee prevails at the hearing, the Commissioner’s findings shall include the date on which the employer’s obligation to pay compensation under this chapter began. The award shall include interest at the statutory rate computed from that date on the total amount of unpaid compensation. (Amended 1997, No. 19, § 4.)

Notes of Decisions

Cited in 7 cases, 1990–2015 · leading case: Adams v. State, 261 P.3d 758 (Alaska 2011).

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Adams v. State, 261 P.3d 758 (Alaska 2011). “" Vt. Stat. Ann. tit. 21, § 664 (1990). The court refused to vacate an award issued more than sixty days after the hearing and stated: A statutory time period is not mandatory unless it both expressly requires an agency or public official to act within a particular time period…”

Smiley v. State, 2015 VT 42 (Vt. 2015). · cites it 2× “[8] This is because the commissioner’s award includes interest at the statutory rate, 21 V.S.A. § 664, and the statutory rate in Vermont is twelve percent, 9 V.”

Ronald Coleman v. United Parcel Serv., 582 A.2d 151 (Vt. 1990). · cites it 2× “In this appeal from a decision of the commissioner of labor and industry granting plaintiff disability benefits, defendant United Parcel Service claims that the award must be reversed because it was not made within 60 days of hearing as mandated by 21 V.S.A. § 664 (“Within sixty…”

Close v. Superior Excavating Co., 693 A.2d 729 (Vt. 1997). “See 21 VS.A. § 664 (Commissioner shall make award setting forth findings of fact and law applicable thereto).”

Peabody v. Home Ins., 751 A.2d 783 (Vt. 2000). “” 21 VS.A. § 664 (emphasis added). Appeals from the Commissioner’s decision may be made to the superior court or this Court.”

Bentley v. Aero Energy, Inc., 903 S.W.2d 912 (Ky. Ct. App. 1995). “We hold, therefore, that exceeding the time limit of 21 V.S.A. § 664 does not deprive the commissioner of jurisdiction.”

Mccurry v. Indus. Com'n of Arizona, 261 P.3d 776 (Ariz. Ct. App. 2011). “” Vt. Stat. Ann. tit. 21, § 664 (1990). The court refused to vacate an award issued more than sixty days after the hearing and stated: A statutory time period is not mandatory unless it both expressly requires an agency or public official to act within a particular time period…”

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