In Appropriate Technology Corp. v. Palma, 146 Vt. 643, 508 A.2d 724 (1986), the defendant worked for the plaintiff for a promise of payment in stock and a very low salary because the corporation was undercapitalized, and quit under family financial pressures.
Unknown to the defendant, the plaintiff's president received a substantial capital contribution to the corporation and intentionally failed to disclose it to defendant.
The defendant brought a counterclaim for the value of the promised stock, and was awarded punitive damages.
The Court affirmed because the "president knowingly misrepresented plaintiff's finances, and that . . . misrepresentation induced defendant to leave the corporation's employ." Id. at 648, 508 A.2d at 727.