From the Editor:
As I have been on trial Chris Potenza has offered up the following note on two cases he reported on relating to cave-in fatalities and the applicability of Labor Law 200 which identify and distinguish the two available types of 200 cases, defect on the property or the means and method of the work being performed in lieu of my usual rambling comments. Thanks Chris.
There are two interesting, and seemingly competing decisions on Labor Law § 200/ common-law negligence from the Third Department on cases with similar fact patterns. Both cases involve a fatality during excavation work at a residential construction project in which the unsecured trench walls buried the plaintiff. In Peck v Szwarcberg, the Third Department granted summary judgment to the defendant property owner as there was no evidence that defendant exercised any supervisory control over decedent's work in the trench installing the drain pipes, or any aspect of the construction project. Conversely, in Mayer v Conrad, the Third Department denied summary judgment to the defendant property owner in which the plaintiff died while working in a trench smoothing concrete when the trench collapsed onto him. The Court in Mayer reasoned that the embankment was “transformed ... into a premises condition” inasmuch as it remained in that condition for several weeks prior to decedent's accident and neither decedent nor any other co-workers were working on the embankment at the time of the accident. There are two main distinctions in these cases however. In Peck, the decedent plaintiff was performing the excavation work when the unsecured walls collapsed on him. In Mayer, the decedent plaintiff was performing ancillary work in the already established, yet unsecured, excavation trench, and the unsecured walls of this trench were an open and visible hazard on the property for weeks. Further, the property owner in Peck was in no way involved in the construction project aside from hiring the contractor, while in Mayer, the defendant property owner was “in the construction business”, visited the site daily, met with the contractor regularly, and even owned the excavator that the contractor used on this project. These facts bolstered the argument that the property owner defendant knew or should have known that the seven- to nine-foot-high unsecured embankment that had been on the property for weeks posed a danger to the workers at the work site.
David
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Blanco v NBC Trust No. 1996A
November 6, 2014
Appellate Division, First Department
Blanco was an electrician allegedly injured while replacing ballasts on 25 light fixtures using an A-frame ladder. Blanco fell when the ladder he was attempted to descend swayed. The trial granted defendants NBC Trust, NBC Universal and Cross Consulting, along with third-party defendant Atlast-Acon motions to dismiss Blanco’s Labor Law § 240(1) claim.
The First Department reversed dismissal of the § 240(1) claim because Blanco’s work at the time of his accident was an activity covered under the statute as it was performed in the context of a larger renovation project at the premises and did not constitute routine maintenance.
Additionally, the court searched the record under CPLR § 3212(b) and granted Blanco partial summary judgment on his § 240(1) claim because of the undisputed evidence as to how the accident occurred and the lack of evidence that Blanco was not the sole proximate cause.
PRACTICE POINT: Interesting here is that the court did not say that changing ballasts was n and of itself a protected project providing protection under the labor law as an alteration, leaving that question for another day.
Hill v Acies Group, LLC
November 6, 2014
Appellate Division, First Department
Hill testified that he was performing his assigned work of cleaning debris from the ground level, just outside the north side of a building under construction, when he was suddenly struck by a falling brick. Defendants’ witnesses confirmed that the brick fell out the hands of a masonry worker several stories above Hill, and that safety netting which had been installed on certain sides of the building, was absent from the north side. The trial court denied Hill’s motion for summary judgment on his Labor Law § 240(1) claim.
Labor Law § 240(1) (DRA)
The First Department held Hill established entitlement to summary judgment because the court determined that the lack of overhead protection was a proximate cause of Hill’s injuries under any of the conflicting accounts of how the accident occurred, and that Hill’s comparative negligence is not a defense to this claim.
The court also rejected defendants’ argument that Hill had been instructed not to cross the barricade or go underneath the scaffolding while any work was being performed overhead because “an instruction by an employer or owner to avoid using unsafe equipment or engaging in unsafe practices is not a safety device in the sense that Hill’s failure to comply with the instruction is equivalent to refusing to use available, safe and appropriate equipment.” The court further held that the conflicting accounts of “what type of work he was doing at the time of the accident” do not raise a triable issue of fact.
PRACTICE POINT: More is needed to establish a sole proximate cause defense than simply telling the employee not to work in an unsafe manner. Here, it appears that it is also not sufficient to tell the plaintiff not to work in a specific area where it is know that there are not adequate safety devices.
Miranda v NYC Partnership Hous. Dev. Fund Co., Inc.
November 13, 2014
Appellate Division, First Department
Miranda allegedly was injured when he fell from a 6-foot-tall A-frame ladder that had been placed atop an 8-foot tall scaffold, reaching a combined height of nearly 14 feet. The trial court granted Miranda’s motion for summary judgment on his Labor Law § 240(1), and denied, as academic, Miranda’s motion on his § 241(6) claim.
Although defendants argued that Miranda could have extended the scaffold to a height of 12 feet using “piping and planks,” the presence of which Miranda disputes, the First Department held the existing scaffold and unassembled components would have constituted an adequate safety device. Even at 12 feet, the scaffold would still be inadequate as Miranda was required to attach sheetrock to a metal frame approaching the 20-foot ceiling.
The court also rejected defendants’ argument that Miranda knew he was expected to use the taller ladders at the worksite as Miranda testified he could not use them because they were designated for use by the plumbers, and the affidavit by defendant Jace Construction’s foreman simply stated that Miranda was not warned against using them.
Thus, the First Department held that because Miranda was not provided with an adequate safety device, defendants cannot avail themselves of the “sole proximate cause” or “recalcitrant worker” defense, and awarded summary judgment in favor of Miranda.
PRACTICE POINT: Remember the three elements necessary for the sole proximate cause defense, an 1) available and 2) appropriate safety device which 3) the plaintiff has been instructed to use or knew he was required to use which the plaintiff, for no good reason chose not to use or misused. Here the court held that neither of the first 2 elements were met.
Defendants did not move for summary judgment dismissing plaintiff’s Labor Law § 241(6) claims; however, the court opted to search the record, and found that the § 241(6) claim, insofar as it is predicated on a violation of 12 NYCRR 23-1.7(f), should be dismissed because plaintiff was not attempting to access another working level within the meaning of § 23-1.7(f)
Kircher City of New York
November 18, 2014
Appellate Division, First Department
Kircher was working on flooring, which was comprised of wooden planks with gaps between them, seven stories above the bottom of a shaft. Plaintiff fell into the shaft and sustained injuries. The trial court granted Kircher’s motion for summary judgment on his Labor Law § 240(1).
Labor Law § 240(1) (DRA)
The First Department reversed the trial court’s decision to conclude that while flooring made of wooden planks with gaps was an elevated-related hazard under the statute, regardless of whether the flooring was permanent that triable issues of fact exist as to whether the work in which Kircher was engaged when his accident occurred constituted routine maintenance or a repair covered under the statute.
PRACTICE POINT: First it seems that flooring covering a seven story shaft is exactly the type of hazard the statute was enacted to protect workers from if engaged in one of the protected activities. In the instant case however the court found a question of fact as to the type of activity engaged in finding a question of fact as between routine maintenance or repair.
Farias v Simon
November 18, 2014
Appellate Division, First Department
Farias, a laborer, was injured in a fall from a scaffold while working on a renovation project at the owners’ one-family house. Defendants Simon, Jr. and Parry (“owners”) acquired title to the house and began renovations in 2005. Parry testified the owners renovated the house for updates and using it as their second home. As the renovation was ongoing, the house was unoccupied at the time of Farias’ injury. The renovation reached the punch list stage in the fall of 2006. The owners never occupied the house, and decided to lease it out in the spring of 2007.
Prior to the renovation, the house needed only minor work consisting of painting, cleaning and “a little bit of fixing up” in order for it to be rented, sold or occupied. The renovation entailed, among the things, the extension of the house, rewiring, plus the addition of a kitchen, a bedroom, two bathrooms, a mud room and a powder room.
The trial court granted the motion of the owners to dismiss the complaint, and denied Farias’ motion for partial summary judgment on his Labor Law § 240(1) claim. The issue on appeal is whether the trial court properly applied the homeowners’ exemption and determined that the work Farias was performing at the time of his accident was for the owners’ commercial use of the house.
The First Department held the owners made a prima facie showing of entitlement to the exemption by demonstrating their premises consists of a one-family dwelling and that they did not direct or control Farias’ work. Thus, the burden shifted to Farias and the court rejected Farias’ speculative argument that the owners intended to use the house solely for commercial purposes and “would not have been able to rent the dilapidated house without undertaking the construction project.”
The court further rejected the dissent’s view that the owners’ intention to make personal use of the premises “is not readily determinable on a motion for summary judgment.” Thus, the majority affirms dismissal of the complaint against the owners and that Farias failed to meet his burden in establishing the existence of material issues of fact.
Justice Gische dissents and would deny the owners’ motion for summary judgment as neither Parry nor Simon, Jr. nor any other member of their family lived there and no one did so during the renovation work. Notably, after the renovation work was completed, the house was rented out to a third-party and used solely for commercial purposes. The dissent would deny the applicability of the homeowners’ exemption because the owners’ purpose in making the renovations is to prepare the property for commercial rental.
In support of their motion, the owners claimed that at the time of the accident in 2005, they had no intention of using the property commercially. Although the dissent recognizes that it is defendants’ intended use at the time of the accident that controls the outcome of the inquiry, there are sufficient facts in the record from which a trier of fact could conclude that defendants’ stated intention is not credible. The dissent notes that the owners freely admit that at some point during the renovation work they decided to use the property commercially, but only did so after Farias’ accident.
PRACTICE POINT: Recall that the homeowner exception is only available for property used for personal residential, and not commercial, purposes at the time of the accident. Here at the time of the accident defendant did not have any purpose for the property which was not residential but rather commercial. The eventual use made of the property is not relevant to the point in time when the accident occurred.
Banegas v Farr
November 19, 2014
Appellate Division, Second Department
Defendant hired Banegas to clean insulation on the roof of their home, and he allegedly fell from the roof and was injured. Defendants moved for summary judgment dismissing the Labor Law §§ 240(1) and 241(6) claims, and Banegas cross-moved on his § 240(1) claim. The trial granted the motion under the homeowners’ exemption, and denied the cross-motion.
The Second Department held defendants made a prima facie showing of entitlement to the exemption by demonstrating that their home was a single-family residence and they did not supervise the methods or manner of Banegas’ work.
PRACTICE POINT: Once again, if the both elements are met, that it is a single family or two family home, not used for commercial purposes and that the defendant did not supervise, direct or control the means and manner of the work being done, then the property owner is exempt from the labor law.
Nicoletti v Iracane
December 19, 2014
Appellate Division, Second Department
Nicoletti was hired as a subcontractor to resurface a deck attached to defendant’s home. Before beginning any actual work, Nicoletti went to the home to assess how he would perform the work. While walking on the deck, it caved in and he fell, allegedly sustaining injuries. The trial court granted defendant’s motion to dismiss the complaint alleging common-law negligence and a violation of Labor Law § 200.
Labor Law § 200 and Common-Law Negligence (VCP)
The Second Department affirmed the trial court’s dismissal of the complaint alleging common-law negligence and a violation of Labor Law § 200. Here, the defendant property owner did not meet her initial burden of showing that she neither created the dangerous condition nor had actual or constructive notice of it. A defendant has constructive notice of a defect when it is visible and apparent, and has existed for a sufficient length of time before the accident such that it could have been discovered and corrected. When a defect is latent and would not be discoverable upon a reasonable inspection, constructive notice may not be imputed. In opposition, the plaintiff failed to raise a triable issue of fact.
Luebke v MBI Group
November 20, 2014
Appellate Division, First Department
Luebke allegedly was injured when he attempted to exit the building through a glass door, and the door fell on him because pins had come loose from the hinges. The trial court granted Luebke’s motion for reargument and denied defendants Pinnacle and Prudential’s motion for summary judgment dismissing the complaint alleging common-law negligence and a violations of Labor Law §§ 200 and 241(6) predicated upon 12 NYCRR § 23-3.3(f).
Defendants failed to establish their entitlement to summary dismissal of the Labor Law § 241(6) claim. Contrary to their argument that plaintiff was not injured at a “building or other structure in the course of demolition” (§ 23-3.3[f]), the gut renovation project involved the destruction of interior walls, which altered the structural integrity of the building and therefore constituted demolition. Defendants also failed to establish that plaintiff’s accident was not caused by a failure to provide “safe access to and egress from” the building, which “shall consist of entrances ... so protected as to safeguard the persons using such means from the hazards of falling ... materials” (12 NYCRR 23-3.3[f]).
Labor Law § 200 and Common-Law Negligence (VCP)
The First Department held that the defendants failed to establish that they did not have actual or constructive notice of this dangerous work site condition, and thus are not entitled to summary dismissal of the Labor Law § 200 and common-law negligence claims. Defendant Pinnacle's project manager and defendant Prudential's facilities director failed to recall whether it was before or after plaintiff's accident that they saw a defective hinge on the door. Issues of fact are also raised by apparent discrepancies in the documentary evidence submitted by defendants as to when the door hinges were repaired, as well as by an affidavit from plaintiff’s foreman, who averred that the door repeatedly became dislodged from its frame when he walked through it during the one-week period immediately preceding the accident, and that Pinnacle's project manager and laborers repeatedly used the door as it was the only means of ingress or egress on the site.
Mayer v Conrad
November 21, 2014
Appellate Division, Fourth Department
Third-party defendant Fisher Concrete (“Fisher”) was hired to perform excavation work on defendants’ property for the construction of a new home. Mayer’s decedent, an employee of Fisher, was working in a trench smoothing concrete when the trench collapsed onto him, inflicting fatal injuries. The trial court granted defendants and Fisher’s motions to dismiss the Labor Law §§ 240(1) and 241(6) claims, but denied the motion with respect to the § 200 and common-law negligence claims.
Labor Law § 200 and Common-Law Negligence (VCP)
Cases involving Labor Law § 200 fall into two broad categories: namely, those where workers are injured as a result of dangerous or defective premises conditions at a work site, and those involving the manner in which the work is performed. Defendants and Fisher argued that this is a “manner and method of work” case and thus that defendants are entitled to summary judgment dismissing the Labor Law § 200 claim and common-law negligence cause of action because they did not have the authority to supervise or control the work. That argument was rejected by the trial court and the Third Department. The Court reasoned that Fisher's excavation work created the dangerous condition at issue here, i.e., the unsecured embankment, however the embankment was “transformed ... into a premises condition” inasmuch as it remained in that condition for several weeks prior to decedent's accident and neither decedent nor any other employee of Fisher were working on the embankment at the time of the accident.
The defendants and Fisher failed to establish that the defendant property owner - lacked actual or constructive notice of the dangerous condition on the premises. The record establishes that defendant visited the construction site every morning, including on the date of the accident, that he engaged in regular conversations about the project with Fisher's owner, and that the condition had existed for two to three weeks prior to the accident, and that it was visible as opposed to latent. Further, although defendant denied that he had any specialized training or expertise in excavation, he testified that he works “in construction,” that he cleared and graded the site in preparation for construction, and that he owned one of the excavators that Fisher used during the course of the project. We thus conclude that there is an issue of fact whether the property owner defendant knew or should have known that the seven- to nine-foot-high unsecured embankment posed a danger to the workers at the work site, and whether he should have taken steps to remedy that condition.
Indemnity Issues in Labor Law (SEP)
As referenced above, the Court aptly noted that the trial court previously dismissed plaintiff’s claims of Labor Law § 240(1) and Labor Law § 241(6). The only action pending against defendant was Labor Law § 200, which, of course, requires a finding of negligence against defendant. Under such circumstances, vicarious liability is removed and defendant’s only exposure is that percentage of fault that is attributable to them as determined by the trier of fact. Because a party cannot shift exposure for their own fault, via common law indemnity (or contractual for that matter), it followed there was no basis for the third-party action.
Vinasco v Intell Times Sq. Hotel, LLC November 26, 2014
Appellate Division, Second Department
Vinasco was working for nonparty United Steel, who was hired by defendants to remove a 200 pound metal gate on their premises. Vinasco was allegedly injured while removing the gate, which was being hoisted from the building, while he stood on an unsecured ladder and was not wearing a safety harness. As he pulled on a cable around the hoisted gate, the gate fell and struck him and the ladder, propelling them to the ground.
He filed this Labor Law § 240(1) action against defendants, and moved for a directed verdict on his claim at the close of evidence at trial. The trial court denied the motion and the jury returned a verdict in favor of defendants, finding they did not fail to provide proper protection to him.
Labor Law § 240(1) (DRA)
The Department held the trial court erred in denying Vinasco’s motion under CPLR § 4401 for judgment as a matter of law as the court, viewing the evidence most favorably to defendants, must conclude that there is no rational process by which the jury could base a finding in favor of defendant. Here, the court held the jury could not rationally have concluded that the hoist which was holding the gate was adequate under the statute, that the unsecured ladder from which Vinasco fell afforded him proper protection, or that the inadequacy of the hoist and ladder was not the proximate cause of the injury.
PRACTICE POINT: Either way you view this case the result appears to be the same, falling object or falling worker. First the falling object, the gate was an item being hoisted and was not properly secured, causing it to fall and cause injury to the plaintiff. Second as a falling worker case the ladder moved causing the plaintiff to fall and thus was not so placed as to protect the plaintiff and thus was not an adequate safety device.
Peck v Szwarcberg
November 26, 2014
Appellate Division, Third Department
Defendant and his wife own a single-family home, and retained an architect to draft blueprint plans, which he used to obtain a permit for the purpose of building a two-story addition to his home with an expanded basement addition. Defendant hired various contractors, including third-party defendant, a construction company retained to excavate and pour the basement foundation and install and connect the drain pipes.
Peck (“decedent”) was a construction worker employed by third-party defendant, performing various excavation work at the site. On the day of the accident, decedent was sent with a coworker to dig a trench and install a footing drain line, and to load materials onto a nearby equipment trailer. The coworker was stacking material while decedent worked alone using the excavator to dig a trench hole six-to-eight feet deep. The trench walls were unsupported and at some point, decedent entered the trench and the walls caved in, burying him and causing death.
Plaintiff, individually and as administrator of decedent’s estate filed this common-law negligence and Labor Law §§ 200, 240(1) and 241(6) action. The trial court granted defendant and third-party defendant’s motions for summary judgment dismissing the respective complaints.
In ascertaining whether a particular homeowner’s actions amount to direction or control of a project, the relevant inquiry is the degree to which the homeowner supervised the method and manner of the actual work being performed by the injured party. That is, “the owner must significantly participate in the project before he or she will be deemed to have crossed the line from being a legitimately concerned homeowner to a de facto supervisor” who is not entitled to the exemption.
Here, third-party defendant’s owner testified that defendant did not direct or control the work; rather, he assigned workers to this job each day, put decedent in charge on the day of the accident, and provided all equipment and materials, for which defendant was billed. He also testified that he discussed how to dig the trench and install the drain, as well as safety measures, with decedent.
The Third Department held that defendant had no prior construction experience and observed the work progress when he was present at his home but that he did not direct the work. Regarding the drain line decedent was installing, the record indicated defendant’s involvement consisted of discussing the local drainage requirements with the workers; and did not tell the workers how or where to install the lines or how to dig the trench. Therefore, viewed in the light most favorably to plaintiff, the court held that defendant was involved in only minor aspects of the project, his “participation was never so significant as to support the conclusion that he directed or supervised decedent’s work” and his actions were simply those of a “legitimately concerned homeowner” and not those of a supervisor.
PRACTICE POINT: Where the defendant does not supervise direct or control the work he is entitled to the exception. The critical language is worth repeating, “the owner must significantly participate in the project before he or she will be deemed to have crossed the line from being a legitimately concerned homeowner to a de facto supervisor”.
Labor Law § 200 and Common-Law Negligence (VCP)
The Third Department reached a similar conclusion with respect to plaintiff's Labor Law § 200 claim, which codifies the common-law duty of owners and general contractors to maintain a safe construction site. As a precondition to the imposition of liability upon defendant as a homeowner, it must be shown that the defendant exercised supervisory control over decedent's work and had actual or constructive knowledge of the unsafe manner in which the work was being performed.
As there was no evidence to support the conclusion that defendant exercised any supervisory control over decedent's work installing the drain pipes or any aspect of the construction project, and the testimony established that the accident was caused by third-party defendant's construction methods, the manner in which decedent excavated, his entry into the trench and/or failure to use available safety devices, plaintiff's Labor Law § 200 and common-law negligence claims against the defendant homeowner necessarily fail.
LABOR LAW § 241(6) REGULATIONS; SPECIFIC OR GENERAL (MAS)
INDUSTRIAL CODE REGULATION |
SPECIFIC OR NOT SUFFICIENTLY SPECIFIC |
CASE LAW |
FACTS |
12 NYCRR § 12-1.4 – Prevention of air contamination. |
§ 12-1.4(a), (b)(1), (2), (3) and (4) are not sufficiently specific. |
Piazza v Frank L. Ciminelli Const. Co., Inc. 2 AD3d 1345 770 NYS2d 504 (4th Dept 2003);
Nostrom v A.W. Chesterton Co., 15 NY3d 502, 914 NYS2d 725 (2010). |
In Piazza, although work performed at apartment and flooring being replaced, π’s work in removing trash from vacant apartment not part of construction. In Nostrom, 2 owners of energy facilities at which decedent worked and GC for the 2 projects were not vicariously liable for π's injuries where liability predicated solely upon violations of regs pertaining to control of air contaminants in the workplace. |
12 NYCRR § 12-1.5(a) – Personal respiratory protective equipment. |
§ 12-1.5(a) and (b) are not sufficiently specific. |
Piazza v Frank L. Ciminelli Const. Co., Inc., supra. |
|
12 NYCRR § 12-1.6 – Personal protective equipment. |
§ 12-1.6(a) cannot serve as a predicate for liability as it is not sufficiently specific. |
Nostrom v A.W. Chesteron Co, supra.; Piazza v Frank L. Ciminelli Const. Co., supra; Pittman v S.P. Lenox Realty, LLC, 119 AD3d 846, 989 NYS2d 359 (2d Dept 2014). |
In Pittman, π died after burned when halogen lamp allegedly ignited liquid π using to refinish floors in apartment; 1.6(a)(3) held inapplicable because accident did not occur in an “unventilated confined area” as required by subsection. |
12 NYCRR § 12-1.8 – Operations using flammable liquids. |
|
Pittman v S.P. Lenox Realty, LLC, supra. |
In Pittman, § 12-1.8(a)(1) did not apply for same reason as 1.6(a)(3); however, § 12-1.8(c)(2)(ii) and (iv) pertaining to lighting requirements in areas where flammable liquids use were also held inapplicable. |
12 NYCRR § 12-1.9 – Entering confined spaces. |
§ 12-1.9(a)(1), (b)(5) and (b)(6) are sufficiently specific. |
Piazza v Frank L. Ciminelli Const. Co., supra; Rivera v Ambassador Fuel and Oil Burner Corp., 45 AD3d 275, 845 NYS2d 25 (1st Dept 2007). |
In Rivera, work π performed involved more than simple cleaning of fuel tank and part of overall contract for installation of new boiler; thus, it could not be said as matter of law that cleaning of tank was not related to construction. |
12 NYCRR § 21.3(d) – Protection of Persons Employed at Window Cleaning; Structural requirements; Equipment and procedures; Defective windows and structures. |
§ 21.3(d) is sufficiently specific. |
Padovano v Teddy’s Realty Associates, Ltd., 56 AD3d 444, 866 NYS2d 743 (2d Dept 2008). |
In Padovano, P fell out of window after losing his balance in trying to open it and although there was evidence premises owner warned worker of problems in opening window, it was error to dismiss Labor Law § 202 claim because it was not demonstrated that § 202 and rules promulgated thereunder were complied with and thus, a triable issue of fact exists as to whether window was defective. |
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Labor Law Pointers
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V. Christopher Potenza
Associate Editor
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Associate Editor
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Labor Law Team
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Dan D. Kohane Cassandra A. Kazukenus
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