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

Vt. Stat. Ann. tit. 21, § 687 (2026)

✓ current as of May 2026
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(Cite as: 21 V.S.A. § 687)
Notes of Decisions
Cited in 11 cases (2 in the last 5 years), 1964–2025 · leading case: Joseph L. LeClair v. Hector LeClair, 169 A.3d 743 (Vt. 2017).
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Joseph L. LeClair v. Hector LeClair, 169 A.3d 743 (Vt. 2017). · cites it 3× “§ 618(b) applies and shifts the burden of proof on negligence and proximate cause to defendant and prevents defendant from relying, as a defense, on assumption of the risk or the negligence of the plaintiff under 12 V.S.A.”
Smith v. Desautels, 2008 VT 17 (Vt. 2008). · cites it 2× “§ 7 (amending 21 V.S.A. § 687(b)). ¶ 21. Subsection (d) of § 618 was not part of the bill as it passed the House of Representatives and later passed second reading in the Senate.”
In Re Chatham Woods Holdings, LLC, 2008 VT 70 (Vt. 2008). “Chatham Woods believes its argument concerning the exemption for sole proprietors extends by analogy to the exemption granted to BK Construction.”
Derosia v. Duro Metal Prods. Co., 519 A.2d 601 (Vt. 1986). · cites it 2× “These include the obligation to secure compensation to employees in one of the enumerated ways, 21 V.S.A. § 687, the failure to comply with the rules and regulations of the commissioner of labor and industry or to pay compensation as required by law, 21 V.”
Quinn v. Pate, 197 A.2d 795 (Vt. 1964). “21 V.S.A. §687. Our concern must be limited, therefore, to a consideration of *125 the act only as between employee and employer, for a consideration of equities between insurance carrier and employee might involve factors that would have no application on a purely…”
Workers' Comp. Div. v. Hodgdon, 759 A.2d 73 (Vt. 2000). “It states: “An employer who fails to comply with 21 VS.A. § 687 (providing workers’ compensation insurance (or self insurance as permitted by law)) may be assessed a penalty of $50.”
Buote v. Verizon New England, 249 F. Supp. 2d 422 (D. Vt. 2003). “See Vt. Stat. Ann. tit. 21, § 687 (Lexis Supp.”
Williams v. United States (2d Cir. 2025). · cites it 5× “21 V.S.A. § 687. According to Williams, the United States did not secure workers’ compensation through any of the means provided by 21 V.”
Williams v. United States (D. Vt. 2024). · cites it 3× “On January 20, 2024, Plaintiff opposed Defendant’s motion, arguing an exception to the exclusive remedy provision applies because the USPS did not secure compensation for its employees as required by 21 V.S.A. § 687. (Doc. 33.) Defendant replied on February 5, 2024, (Doc.”
Lee Chapman, Sr. v. Robert Spaulding Enter., Inc. (Vt. 2011). · cites it 4× “That statute provides that when a corporate employer fails to secure workers’ compensation insurance as required under 21 V.S.A. § 687, then “the officers and majority stockholders of the corporation shall be personally liable for any benefits owed to the injured employee under…”
Chapman v. Robert Spaulding Enter., Inc. (Vt. Super. Ct. 2010). · cites it 4× “Furthermore, the defendant corporation did not carry workers’ compensation insurance, and thus did not secure workers’ compensation under 21 V.S.A. § 687. Finally, 5 defendant Lori Spaulding was vice-president and secretary of the defendant corporation during the period at issue.”
— Vt. Stat. Ann. tit. 21, § 687(a) — 3 cases
In Re Chatham Woods Holdings, LLC, 2008 VT 70 (Vt. 2008). “Chatham Woods believes its argument concerning the exemption for sole proprietors extends by analogy to the exemption granted to BK Construction.”
Williams v. United States (D. Vt. 2024). “On January 20, 2024, Plaintiff opposed Defendant’s motion, arguing an exception to the exclusive remedy provision applies because the USPS did not secure compensation for its employees as required by 21 V.S.A. § 687. (Doc. 33.) Defendant replied on February 5, 2024, (Doc.”
Chapman v. Robert Spaulding Enter., Inc. (Vt. Super. Ct. 2010). “Furthermore, the defendant corporation did not carry workers’ compensation insurance, and thus did not secure workers’ compensation under 21 V.S.A. § 687. Finally, 5 defendant Lori Spaulding was vice-president and secretary of the defendant corporation during the period at issue.”
— Vt. Stat. Ann. tit. 21, § 687(b) — 1 case
Smith v. Desautels, 2008 VT 17 (Vt. 2008). “§ 7 (amending 21 V.S.A. § 687(b)). ¶ 21. Subsection (d) of § 618 was not part of the bill as it passed the House of Representatives and later passed second reading in the Senate.”
— Vt. Stat. Ann. tit. 21, § 687(b)(1) — 2 cases
Lee Chapman, Sr. v. Robert Spaulding Enter., Inc. (Vt. 2011). “That statute provides that when a corporate employer fails to secure workers’ compensation insurance as required under 21 V.S.A. § 687, then “the officers and majority stockholders of the corporation shall be personally liable for any benefits owed to the injured employee under…”
Chapman v. Robert Spaulding Enter., Inc. (Vt. Super. Ct. 2010). “Furthermore, the defendant corporation did not carry workers’ compensation insurance, and thus did not secure workers’ compensation under 21 V.S.A. § 687. Finally, 5 defendant Lori Spaulding was vice-president and secretary of the defendant corporation during the period at issue.”
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