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Labor Law Pointers - Volume X, No. 9

 
 

Labor Law Pointers

A Monthly Electronic Newsletter Addressing
New York State Labor Law Decisions and Trends

Volume X, No. 9
Wednesday, August 4, 2021

 

From the Editor:

Do you have a situation?  We love situations.  Give us a call, send an email, drop by, we truly enjoy solving complex Labor Law and risk transfer issues. 

Summer is in full swing here. The Canadian border opens in a few days, so I will be able to see my cottage for the first time in 18 months, and I wonder what I will find.  While I have had people looking at the cottage, there is no way to tell what type of creature has taken up residence.  My family is sending me to find that out before they venture up. 
 
We have several interesting cases for your reading pleasure this month, including a nice recital of Res Judicata and Collateral Estoppel by Marc in the Bravo v Atlas Capital Group, LLC case below.  Just a reminder that the case names, as well as our names, are hyperlinks, and will either take you directly to the case or open an email to the author of the section.  We encourage you to reach out to us with any questions, and this makes it easy to do so. 
 
Speaking of reaching out, we have been providing some seminars to groups of subscribers and would encourage all of you to reach out and set something up.  Our goal is to share our knowledge to the extent that you can answer your own questions and, if necessary, follow up with us for a quick confirmation of what you now know. 
 
In our first photo of the month, we have a cable installer, hired to install internet to a business, who forgot his ladder, so he decided that he was going to improvise.  He was there to install internet cable in a building where it had never been installed before, and it would require drilling holes in the building to access the interior.  Fortunately, he is a popular guy and several of his friends were available to help steady his makeshift “ladder.”  He had been trained to only ascend a pole using a company provided ladder, with tie offs and rubber feet, but, not having one, this was his solution.  The pole was owned by the electric company and the cable company owned the cables and had a pole use agreement with the electric company.  § 240(1) case?
 

 
In this situation we have a valid defendant, the electric company who owns the pole.  A pole is a structure, being made of component parts.  The plaintiff was a person so employed, thus, a valid plaintiff.  The job, installing internet, involved a physical change to the building and, therefore, was an alteration, a covered operation.  He was injured by the effect of gravity, a covered type of injury causation.  The question becomes whether there is a valid sole proximate cause defense?  Where the plaintiff did not have an appropriate safety device, which was available to him, on site, generally, the answer is no.  I would argue that plaintiff forgot to bring the ladder and thus it was available, but I would not like my chances in the First Department.  I would likely have a much better chance in the Second.
 
Here we have an electrician, installing new lights for the city, on existing poles owned by the city. He works for the city as a journeyman electrician, with twenty-five years of experience and had been trained (on numerous occasions) not to do this job without an appropriate ladder, which was on the truck just feet away.  The plaintiff’s boss was also there, and he was the one who told the plaintiff to “just get on the excavator and we will raise you up, we are running out of time here” minutes before the accident occurred, when plaintiff fell from the bucket of the excavator.  § 240(1) case?
 

 
Plaintiff is a person so employed. The city owns the pole and is a valid defendant. The overall project, installing lights, was a covered activity, either as construction or as an alteration. The injury, when plaintiff fell from a height, was gravity caused.  The defense here, is that the plaintiff will receive workers’ compensation benefits, and thus can’t sue his employer, as under section 11 of the Comp Law, workers’ compensation is the exclusive remedy available to the plaintiff. 
 
In this last photo, the worker was hired by the building to repair the non-functional air conditioning, an activity which seems to need to be done every few weeks, as some offices are arctic, and some tropical, all within a few feet.  When the plaintiff falls because the desk divider his foot is resting on moves, and he falls on the unwitting legal assistant diligently trying to work at her desk, does she have a valid § 240(1) claim for a falling object? 


 
Let’s start at the beginning.  The activity is arguably repair.  Of course, an argument could be made that the constant work on the air conditioning is more akin to constant maintenance. (Yes, this is our office, just this week). The worker was not provided with any additional ladders, and he was doing the best he could with what he was provided, so there is no sole proximate cause defense.  A falling worker is a falling object, so that part works for our valiant plaintiff.  The problem for the plaintiff-to-be is, while she is a person so employed, she is not a person employed in any capacity having to do with the work being done, and her presence under a falling worker is not associated with the work being done, so she is not a valid plaintiff.  Sorry Kathy, at least you would have a good negligence claim.
 
That’s it for this month. As always, feel free to reach out to us with any questions Labor Law or Risk Transfer related and we will be happy to help. 

David

 
David R. Adams
Hurwitz & Fine, P.C.
424 Main Street
Suite 1300 Liberty Building
Buffalo, New York 14202
Phone:  716.849.8900
Direct:  716.849.8916
Fax:  716.855.0874
Cell:  716.553.6901
Email:  [email protected]
H&F Website:  www.hurwitzfine.com

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Bravo v Atlas Capital Group, LLC
July 21, 2021
Appellate Division, Second Department

 
In his prior action, plaintiff alleged that Eastgate was the owner, lessee, operator, and the entity responsible for maintenance of a 25-story building undergoing construction, renovation, and demolition. Plaintiff was allegedly injured when a forklift his coworker was operating struck his foot (the forklift incident). The trial court granted Eastgate’s motion for summary judgment dismissing the Labor Law §§ 240(1), 241(6), 200, and common-law negligence claims. Plaintiff failed to perfect his appeal from the Order in that prior action.
 
Plaintiff thereafter commenced this action against defendants Atlas and Total Safety as a result of the forklift incident. Atlas owned the project and retained Legacy to act as the general contractor. Plaintiff, a Legacy employee, was supervised exclusively by Legacy personnel. Atlas hired Vesta to perform facade repair. In turn, Vesta hired TSC to provide site safety management services for the facade work. The trial court granted the separate motions of Atlas and Total Safety to dismiss plaintiff’s complaint against them based on the principles of res judicata and collateral estoppel, since plaintiff asserted the same claims in this case as in his prior action. 
 
Labor Law § 240(1) (MAS)
The First Department reversed as to Atlas, who failed to demonstrate that the determination in the prior action against Eastgate was dispositive in this action against it by virtue of Atlas’s privity with Eastgate. In support of its motion, Atlas submitted the affidavit of its chief financial officer, who averred that Eastgate was “a wholly owned subsidiary of the joint venture managed by Atlas” and that it “was the special purpose entity that acted as the fee owner of the property.” However, the affidavit failed to establish a connection between the interests of Atlas and Eastgate sufficient to establish privity. Atlas’s construction manager testified at his deposition in the prior action that Atlas was not the sole shareholder of Eastgate, and it rented the forklift. Since Atlas was not a party to the prior action and failed to establish that it was in privity with Eastgate, neither res judicata nor collateral estoppel barred plaintiff’s action against Atlas.
 
The First Department dismissed the complaint against Total Safety, who established its prima facie entitlement to judgment as a matter of law by proving that it did not have the authority to control or supervise the performance of the injury-producing work. Plaintiff also failed to show that further discovery might lead to relevant information regarding Total Safety’s liability.
 
PRACTICE POINT: Res judicata bars litigation between the same parties, or those in privity with them, of a claim arising out of the same transaction(s) as a claim that either was raised or should have been raised and determined in a prior proceeding. Collateral estoppel only applies to parties who were either a party, or in privity with a party, to a prior action or proceeding, and bars relitigating an issue which necessarily has been decided in that prior action or proceeding and is determinative of the issues disputed in the present action, provided there was a full and fair opportunity to contest the decision now alleged to be controlling. Although relationship alone is not sufficient to support preclusion, “privity includes those who are successors to a property interest, those who control an action although not formal parties to it, [and] those whose interest are represented by a party to the action.” The party asserting the conclusive effect of a prior judgment has the burden of establishing it. In this case, Atlas failed to meet its burden of demonstrating that either res judicata or collateral estoppel applied to bar plaintiff’s claims against it.
 
 

Garcia v Emerick Gross Real Estate, L.P.
July 28, 2021
Appellate Division, Second Department

 
Defendant/Third-Party Plaintiff Emerick hired third-party defendant, TSI, to make certain improvements to a boiler in one of Emerick’s multifamily dwellings in Brooklyn. Plaintiff, an employee of TSI, allegedly was injured when a ladder he was using to perform his work in the boiler room suddenly shifted and caused him to fall. He allegedly was supplied the ladder by Emerick’s employee. The trial court denied plaintiff’s motion for partial summary judgment on liability against Emerick, denied Emerick’s cross-motion to dismiss the complaint and on its contractual indemnity claim, and granted plaintiff’s cross-motion for sanctions against Emerick for spoilation of evidence to the extent of determining that plaintiff is entitled to a negative inference against it at trial.
 
Labor Law § 240(1) (MAS)
The Second Department affirmed denial of plaintiff’s motion as he failed to establish, prima facie, that the ladder he was using to perform his work at the express or implied direction of both Emerick and TSI unexpectedly failed, and that the lack of an appropriate safety device was a proximate cause of his injuries. Emerick submitted deposition testimony of TSI’s owner, who explained that functional TSI ladders were available for plaintiff’s use on the day of his accident, TSI forbids employees from using non-TSI ladders, and that plaintiff did not otherwise have express or implied permission to use Emerick’s allegedly defective ladder. Therefore, the record as compiled by Emerick raised triable issues of fact as to whether plaintiff was a recalcitrant worker and therefore the sole proximate cause of his injuries.
 
PRACTICE POINT: Recall that, to establish a sole proximate cause defense, such that a defendant has no liability under Labor Law § 240(1), it must prove plaintiff: (1) had adequate safety devices available; (2) knew both that the safety devices were available and that he or she was expected to use them, (3) chose for no good reason not to do so, and (4) would not have been injured had he or she not made that choice. Here, Emerick raised a triable issue of fact to defeat plaintiff’s summary judgment motion as to whether plaintiff was a recalcitrant worker under Labor Law 240(1). Emerick’s proof showed that plaintiff was provided with safety devices, such safety devices were readily available for his use, plaintiff was previously instructed not to use non-TSI ladders, for no good reason, he chose to use Emerick’s ladder rather than TSI’s ladder, and he would not have been injured if he used TSI’s ladder.
 
Labor Law § 200 and Common-Law Negligence (ESB)
The Second Department affirmed denial of both plaintiff’s and Emerick’s respective motions for summary judgment as to Labor Law § 200 and common-law negligence. It held that, in this “dangerous condition on the premises” case, although plaintiff demonstrated that Emerick had actual or constructive notice of uneven flooring in the boiler room, and that the allegedly dangerous condition was a proximate cause of his injuries, there remained triable questions of fact regarding whether plaintiff was a recalcitrant worker and therefore the sole proximate cause of his injuries.
 
 

Stockton v H&E Biffer Enters. No. 2, LLC
July 28, 2021
Appellate Division, Second Department

 
Plaintiff, a mechanic employed by nonparty HVAC company, allegedly sustained injuries after falling off a ladder while performing a nonemergency service call at the Park Store. He testified at his deposition that after inspecting a refrigeration unit on the roof, he determined the “condenser fan motor was vibrating,” and required replacement. At the time of his accident, plaintiff was climbing a ladder to return to the roof to complete the replacement of the condenser fan motor. After he fell, he replaced the ladder, climbed to the roof, and replaced the motor, which took forty-five minutes.
 
The trial court granted defendants’ motion for summary judgment dismissing the Labor Law 240(1) claim and denied plaintiff’s cross-motion for partial summary judgment on that claim.
 
Labor Law § 240(1) (MAS)
The Second Department affirmed because defendants established, prima facie, that the replacement of the condenser fan motor, which according to the deposition testimony, weighed 1½ pounds and was the kind of part that required replacement “all the time”. Therefore, the Court held plaintiff’s work constituted routine maintenance and not repairing, or any of the other enumerated activities under Labor Law § 240 as the work here involved replacing a component that requires replacement in the course of normal wear and tear (see Tserpelis v Tamares Realt Estate Holdings, Inc., 147 AD3d 1001, 1002 [2d Dept 2017]).
 
PRACTICE POINT: It is very important to recognize that Courts distinguish repair work from routine maintenance. Routine maintenance falls outside the scope of Labor Law § 240(1) because it involves “replacing components that require replacement in the course of normal wear and tear.” In this case, plaintiff's work constituted routine maintenance and not repairing or any of the other enumerated activities.
 
 

Edwards v State Univ. Constr. Fund
July 1, 2021
Appellate Division, Third Department

 
Plaintiff was injured during the renovation of SUNY Oneonta's Physical Sciences Building (the Building), when he allegedly hit his head on a wooden beam supporting a scaffold, causing him to fall backwards down a set of stairs. On the morning of his accident, he had been directed by Ivan Cote – the superintendent of the project and Ralo’s President, to remove debris from the roof the Building. Plaintiff positioned an extended lift flush with the roof as makeshift dumpster, went inside and ascended the stairwell to access the roof, looking down at his feet while he walked to avoid potential trip hazards. As he approached the third floor, he “all of sudden” saw a “bright flash” and fell backwards. He admitted to not seeing the beam prior to impact and while he could not specifically recall hitting anything, he denied tripping on the stairs and posited, due to a cut on the bridge of his nose, that he hit his head on the low clearance beam.
 
The trial court (1) denied defendants State University Construction Fund (SUCF) and Fahs Construction’s motion for summary judgment dismissing the complaint against them, (2) partially granted defendant Duffek’s motion for summary judgment dismissing the complaint against it, and (3) denied third-party defendant Ralo’s motion for summary judgment dismissing the third-party complaints.
 
Labor Law § 241(6) (TPW)
As to the Labor Law § 241 (6) claims, the Appellate Division, Third Department affirmed the lower court’s determination that there were triable issues of fact regarding the sufficiency of the lighting in the stairwell at the time of the accident (Industrial Code 12 NYCRR 23-1.30), thereby precluding dismissal of that claim as asserted against SUCF and Fahs given the testimony that the staircase "wasn't lit up very well" and that it was hard to see beyond "probably four feet." Also, when shown a picture of the stairwell during his deposition, Edwards opined that the picture was too bright to be a fair representation of the lighting on the day in question.  It was also noted that there had been issues with the lighting conditions in the stairwell, noting that drop lights had been installed prior to the accident because "in the mornings the stairwell was dark."  Finally, the decision was further affirmed in that the Labor Law § 241 (6) claim against Duffek could not be maintained as there was no proof that it was a statutory agent with responsibility for the alleged violation.
 
Labor Law § 200 and Common-Law Negligence (ESB)
The Third Department affirmed denial of the motions of SUCF and Fahs for summary judgment as to Labor Law § 200 and common-law negligence. It held that, although SUCF and Fahs argued the plaintiff’s injuries arose from the means and methods of the work, the evidence demonstrated that it arose from a dangerous condition on the premises. Plaintiff testified that, on the morning of the incident, he had been directed to remove debris from the roof of the building. He first positioned an extended lift flush with the roof as a makeshift dumpster, went inside and ascended the stairwell to access the roof, looking down at his feet while he walked to avoid potential trip hazards. As he was approaching the third floor, plaintiff “all of a sudden” saw a “bright flash” and fell backwards.
 
As there was no assertion that the scaffold or the support beam were defective, and no evidence that the manner in which plaintiff intended to perform his work was a cause of the accident (the scaffold was erected prior to the accident, the injury did not derive from any work performed on the scaffold and plaintiff was not engaged in his cleanup responsibilities at the time of the incident), the trial court properly found the placement of the beam created the hazard, and only a “dangerous condition” theory of liability was viable. Applying that theory of liability, questions of fact arose regarding both defendants’ control over the premises and notice of the hazardous condition.
 
Indemnity Issues in Labor Law (BFM)
The Third Department agreed with the trial court’s finding that the indemnification provision in Ralo's subcontract agreement with Fahs was enforceable.  Not only does the indemnification provision include a savings clause providing indemnification only “[t]o the fullest extent permitted by law”, but, by its plain language, it obligated Ralo to indemnify SUCF for losses attributable to the actual or alleged negligence of Ralo or its employees, not of SUCF or Fahs.  However, due to issues of fact as to whose negligence, if any, caused the accident, the Third Department reversed the trial court’s award of contractual indemnification to SUCF and Fahs at the summary judgment phase finding same to be premature.

The Third Department also reversed the trial court’s denial of that portion of Ralo's motion which sought to dismiss the breach of contract claims for failing to procure insurance as Ralo established that it procured the required insurance policy and neither SUCF nor Fahs opposed the motion.

 

Fuhlbruck v 3170 Del., LLC
July 9, 2021
Appellate Division, Fourth Department

 
Plaintiff allegedly sustained injuries while cleaning the exterior windows of the rental store he managed, located at defendant 3170 Delaware’s premises. Plaintiff was directed by his supervisor to clean the exterior windows of the store. He was provided a squeegee and told to extend its reach using a broom handle. While cleaning, he used an eight-foot ladder but worked at a maximum elevation of five feet. The top of the windows were nine to ten feet above ground. The trial court denied plaintiff’s motion for partial summary judgment and granted defendant’s cross-motion for summary judgment and dismissed plaintiff’s complaint.
 
Labor Law § 240(1) (MAS)
The Fourth Department unanimously affirmed, finding that plaintiff was not engaged in cleaning related to “any ongoing construction, renovation, painting, alteration, or repair project” and the trial court properly weighed the factors in determining that plaintiff was not engaged in the type of cleaning covered under Labor Law 240(1). Defendant established the cleaning was of the type that would be conducted routinely – i.e., on a regular schedule and with relative frequency – in a retail setting.
 
The Fourth Department rejected plaintiff’s contention that the cleaning cannot be considered “routine” because he had cleaned the exterior windows only once in the four years preceding the accident and was unaware of any other person cleaning those windows during that time. The Court further noted that plaintiff worked at an elevation of five feet, “a height that presents an elevation-related risk comparable to that encountered during ordinary domestic or household cleaning (see Holguin v Barton, 160 AD3d 819, 819-820 [2d Dept 2018]).
 
PRACTICE POINT: Labor Law § 240(1) applies to various types of cleaning projects. However, except for commercial window cleaning, an activity cannot be “cleaning” under the statute if the task: (1) is routine, in the sense that it is the type of job that occurs on a daily, weekly, or other relatively-frequent and recurring basis, as part of the ordinary maintenance and care of commercial premises; (2) requires neither specialized equipment or expertise, nor the unusual deployment of labor; (3) generally involved insignificant elevation risks comparable to those inherent in typical domestic or household cleaning; and (4) in light of the core purpose of Labor Law § 240(1) to protect construction workers, is unrelated to any ongoing construction, renovation, painting, alteration or repair project” (see Soto v J. Crew Inc., 21 NY3d 562, 568 [2013]). Here, the fourth factor did not apply, and the other three factors weighed against plaintiff as his injury-producing work did not qualify as “cleaning” under Labor Law 240(1).
 
 

Tanksley v LCO Bldg. LLC
July 9, 2021
Appellate Division, Fourth Department

 
Plaintiff was allegedly injured when he fell through a skylight hole on a roof while working on a construction project. He brought this Labor Law and common-law negligence action against defendants LCO, Cityview, and defendant-third-party plaintiff SAB. SAB subsequently sued third-party defendant Blas Zuniga for contractual indemnification. The indemnity provision in the Blas Zuniga/SAB subcontract provides that Blas Zuniga agreed to indemnify SAB against all claims “for or on account of any injury to any person …which may arise (or which may alleged to have risen) out of or in connection with performance of contract work” by Blas Zuniga. The trial court granted SAB’s motion for summary judgment seeking a conditional order of contractual indemnification against Blas Zuniga.
 
Indemnity Issues in Labor Law (BFM)
The Fourth Department affirmed the granting of summary judgment in favor of SAB, finding that Blas Zuniga owed contractual indemnification to SAB.  The Court concluded that SAB established as a matter of law that plaintiff's accident arose out of or in connection with the performance of Blas Zuniga's work, thus triggering the indemnification language in their subcontract.  The Court also found that although the subcontract between Blas Zuniga and SAB was signed after the date of the plaintiff’s accident, there was ample evidence that the parties had reached an agreement prior to the plaintiff’s accident that included the indemnification provision and that they intended the agreement to apply as of that prior date.

 

Field v Pet Haven, Inc.
July 16, 2021
Appellate Division, Fourth Department

 
Plaintiff was injured while working on defendant’s property and commenced a Labor Law and negligence action. Settlement negotiations ensued and defendant’s lawyer eventually sent an email to plaintiff’s lawyer offering to settle the case for $32,500. Plaintiff’s lawyer responded that “[plaintiff] informed me that he would like to accept the $32,500 settlement … Is it possible to email me over a release for this case from your adjuster please?” Plaintiff’s lawyer affixed his name to the bottom of the foregoing email. Within two hours, defendant’s lawyer emailed the requested settlement papers to plaintiff’s lawyer. Plaintiff ultimately refused to execute those papers, and the trial court denied defendant’s motion to enforce the settlement agreement.
 
Labor Law § 240(1) (MAS)
The Fourth Department unanimously reversed the trial court and agreed with defendant that the requirements for a valid and enforceable settlement agreement are satisfied. The email from plaintiff’s lawyer to defendant’s lawyer contained the only two material terms of the agreement, i.e., defendant’s payment of $32,500 to plaintiff in exchange for plaintiff’s release of defendant from further liability; the email plainly manifested the parties’ mutual accord, i.e., “[plaintiff] has informed me that he would like to accept the $32,500 settlement [offered by defendant]”; and the lawyer representing the party to be bound, i.e., plaintiff’s counsel, explicitly typed his name at the end of the email in a manner akin to a hand-signed letter.
 
The Fourth Department held that nothing more was required and plaintiff’s “subsequent refusal to execute form releases and a stipulation of discontinuance did not invalidate the agreement” (see Williamson v Delsner, 59 AD3d 291, 291 [1st Dept 2009]). To the contrary, plaintiff’s refusal to execute the necessary releases and stipulation constituted a breach of the parties’ valid settlement agreement. Accordingly, the trial court should have granted defendant’s cross-motion to enforce the settlement agreement (see Jimenez v Yanne, 152 AD3d 434, 434, [1st Dept 2017]).
 
PRACTICE POINT: Under CPLR 2104, “[a]n agreement between parties or their attorneys relating to any matter in an action, other than one made between counsel in open court, is not binding upon a party unless it is in writing subscribed by him or [her and] his [or her] attorney”. The enforceability of settlement agreements is governed by contract law and “all material terms must be set forth and there must be a manifestation of mutual assent”. In this case, the email contained all the material terms of the settlement, a manifestation of mutual accord, and the lawyer’s typed email signature, which constituted a writing within the meaning of CPLR 2104, such that an enforceable settlement agreement was created by the lawyers’ conduct.

 

 New York Industrial Code Regulations (EDA)

12 NYCRR 23-1.21(f) Ladderways -After June 1, 1972, any ladderway exceeding 70 feet in height shall be equipped with rest platforms spaced at intervals not exceeding 35 feet. Where ladders are used in series and where a danger of falling material or debris exists, such ladders shall be staggered, offset or so located as to provide protection from such danger.

Regulation § 1.21(f) which pertains to ladderways over 70 feet in height, contains specific commands that would likely support a Labor Law § 241(6) cause of action.

 

23–1.21(f) sets forth certain requirements that ladderways must meet.  While no appellate division has ruled on this sub paragraph, it is highly likely it will be found to be sufficiently specific to support a §241(6) claim.

 

 

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