The Vermont Supreme Court recently ruled on a complex case involving Gregory Lamson, James Goode, and Chase Locke. The court's decision, issued on November 13, 2026, addressed disputes over attorney fees and civil extortion claims stemming from a construction contract. This ruling affects the parties involved and clarifies the application of Vermont's Prompt Pay Act.

In this case, Gregory Lamson sold 42 acres of land to James Goode in 2015. Following this sale, Lamson was hired by Goode to construct a pond on another property. Lamson subcontracted Chase Locke to clear the land for the pond. However, disputes arose between the parties, leading Lamson to file a lawsuit in 2017. The lawsuit included claims against Goode for breach of contract and against Locke for breach of contract and conversion.

The disputes escalated, with Lamson alleging that Goode prevented him from completing the pond work and refused to pay him for his services. Lamson also accused Goode of wrongfully using his tractor and preventing access to his equipment. Goode, in turn, filed counterclaims against Lamson, alleging violations of Vermont's Consumer Protection Law and seeking damages for an alleged assault and other claims.

After a jury trial, the court ruled in favor of Lamson on his breach of contract claim against Goode, awarding him $7,500 plus interest. However, Goode was awarded $5,000 on his assault claim, and Locke received $15,100 for his extortion claim against Lamson. Following the trial, both Lamson and Goode sought attorney fees under the Prompt Pay Act, which allows the substantially prevailing party to recover such fees.

The court denied both parties' requests for attorney fees, concluding that neither party substantially prevailed in the case. The court stated, "Neither party obtained what they wanted from the construction dispute," and noted that the defendants collectively received more than Lamson. Goode appealed this decision, while Lamson cross-appealed, arguing he should have been awarded attorney fees and challenging the extortion claim awarded to Locke.

The Vermont Supreme Court reviewed the trial court's ruling on attorney fees, emphasizing that the determination of a substantially prevailing party is left to the trial court's discretion. The court explained that the Prompt Pay Act mandates attorney fees for the substantially prevailing party, but the trial court has the discretion to determine whether any party meets this criterion.

The court noted that the trial court's decision was not based solely on a mathematical calculation of claims won or monetary awards. The court stated, "The test is not a mathematical calculation based on the number of claims won or the amount of money awarded," and recognized that the trial court may conclude that neither party substantially prevailed.

The court further addressed Goode's argument that he should be considered the substantially prevailing party because Lamson abandoned his Prompt Pay Act claim. The court clarified that the Prompt Pay Act is not a means for recovering damages from the underlying contract dispute but rather obligates owners to pay contractors in accordance with the contract terms. Thus, the trial court was not required to find that Goode substantially prevailed based on the jury's good faith finding regarding withheld payments.

On Lamson's cross-appeal regarding the civil extortion claim, the court examined whether Vermont law recognizes a civil remedy for extortion. The court noted that Lamson had previously moved for judgment on the pleadings, arguing that Vermont's criminal extortion statute did not provide for a civil remedy. Initially, the court agreed but later reversed its decision, allowing the extortion claim to proceed based on the precedent set in Hoyt v. Dewey.

The court affirmed the trial court's decision to allow the extortion claim, stating that it aligns with the principles of economic duress. The court instructed the jury to limit its award to the value of the money or property delivered under duress, consistent with restitution principles.

Ultimately, the Vermont Supreme Court affirmed the trial court's ruling, stating that the errors made in considering the claims did not affect the outcome of the case. The court emphasized that neither party achieved a significant victory that warranted an award of attorney fees.

This ruling clarifies the application of the Prompt Pay Act in Vermont and sets a precedent regarding civil extortion claims. It highlights the importance of the trial court's discretion in determining the substantially prevailing party and the complexities involved in construction contract disputes.

Moving forward, this decision may influence how parties approach similar disputes in the construction industry. It underscores the necessity for clarity in contract terms and the potential consequences of disputes over payment and performance.

Details were not available in the court filing regarding any potential appeals or related cases pending.