Labor Law Pointers - Volume XI, No. 11

Volume XI, No. 11 Wednesday, October 5, 2022
 Note from David R. Adams:
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.    We have a light month this month, only seven cases total, but to make up for it we added some videos in place of still photos to enliven our opportunity to entertain and teach simultaneously.  Please note, the videos might take a minute to load onto mobile devices, but we are assured that they will in fact play.    I have presented an update to several carriers in the past few months on the likely impact of The Grieving Families Act, likely to be signed by Governor Hochul shortly after the election, assuming she wins.  For anyone not aware of the Act, it increases the statute of limitations, adds to who can be a plaintiff in the suit from only immediate family to a yet undefined number of people, and, most critically, allows for the currently undefined class of survivor plaintiffs to collect for “grief or anguish caused” by the loss, a category not previously allowed.  These changes will cause increased values for wrongful death cases, especially as the act as currently drafted would apply retroactively to all cases now in suit as well as all new cases.   As you may recall, we highlighted our CAT Team, strategically selected to handle cases with catastrophic injuries and high exposure. I head this team along with select members with specific experience in liability, damages, and risk transfer opportunities to represent our clients in these challenging cases.  The Grieving Families Act makes this team all the more important and timely.  Do not hesitate to call or email to discuss the CAT Team, and how we can help with your worst cases.   In our first video of the month, we have a soon to be plaintiff who was hired by the apartment building owner to remove the concrete roof on a storage area behind the building.  As he stood on the ladder and broke the re-rod holding the roof up, the roof fell, causing the plaintiff to fall from the ladder.  Plaintiff admitted at his deposition that he was instructed by his employer to always open the A-frame ladder, only use it when it was fully open and locked, and that there was no reason he could not have done so here.  § 240(1) case?       The analysis always starts the same: the owner of the building is a proper defendant, the plaintiff is a person so employed and a valid plaintiff, the project was an alteration to a building or structure so it is proper, and the injury was caused by a fall to a different elevation.  Plaintiff thus has a prima facie case for §240(1).  Defendant argues sole proximate cause, that the plaintiff has an appropriate safety device which was available, in fact he was on it, which he was instructed to use but which was misused by his failure to open it, as he could have done by his own admission.  In the end, however, that is not enough.  The falling object that caused his injury, the wall, was an object that should have been secured, was not secured, and struck the ladder causing the fall.  Thus, the plaintiff’s failure to properly use the ladder could not be the SOLE proximate cause as the un-secured falling wall is also a proximate cause.   In our second offering this month, we find a tree trimming service hired by the owner of an office building to cut down a tree which has simply gotten so tall that it is in danger of coming down on cars in the parking lot.  The worker sent up the tree to top it asked his boss could he please use the boom lift to do the job as the tree was going to sway once he topped it.  The owner, Mr. Scrooge, though it would cost too much to rent the lift and told his employee that he could either use the ladder or find a different job.  The worker was provided with a harness and lanyard with which he tied himself to the tree, but when the top fell, he was thrown around so violently that he sustained severe back injuries and a very serious cut from the swinging chainsaw.  § 240(1) case?   To begin, we have a valid plaintiff and a valid defendant.  The injury was clearly caused by gravity--remember that the plaintiff need not actually fall, but could be injured preventing himself from falling.  The real issue here is that he was working on a tree, and only a tree. You will recall that § 240(1) requires that the protected activity be conducted on a “building or structure”.  The courts have consistently held that a structure is something made of component parts, which a tree is not, thus the project is not one protected by § 240(1), and summary judgment for the defendant should follow.   In our third video this month, we have an unfortunate roofer whose company was hired to replace the roof on a storage facility. As he arrived for work on the first day of the job, he leaned his ladder against the back wall and proceeded to try and climb up to start work when the ladder moved, causing him to fall as depicted below.  Adding insult to injury, he fell into a ditch filled with some type of foul liquid.  He knew, and he later testified under oath at the depo, that he should have opened the ladder and locked the braces as he was instructed, and that his failure to do so caused the ladder to fall.  Plaintiff also testified that the ladder was simply not tall enough for him to get to the roof with the ladder open and that there were no other ladders on site.  § 240(1)?     Ok, I will admit it, these scenarios are just too easy this month, but I love the videos.  I am going to have trouble finding enough for each month.  In this one, the sole proximate cause defense based on the plaintiff’s failure to open the ladder will fail, as in the case above, because the lack of an appropriate (taller) ladder is also a proximate cause.  No one is going to find an expert that will testify that the ladder he was using is tall enough to climb to that roof.  It doesn’t even reach the roof, much less extend above the roof sufficiently.  As there will be two proximate causes, neither can be the sole proximate cause, and summary judgment for plaintiff will be granted.   That is it for this month; enjoy the fall and see you next month.   Please feel free to reach out to us with any questions Labor Law or Risk-Transfer related.   
  David R. Adams Hurwitz Fine P.C. The Liberty Building 424 Main Street, Suite 1300 Buffalo, New York 14202 Phone:  716.849.8900 Fax:  716.855.0874 Email:  [email protected] HF Website:
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Rosa v 47 E. 34th St. (NY), L.P. September 13, 2022 Appellate Division, First Department
  Cuevas was employed by Bridgestreet as the building's tenant and resident manager responsible for overseeing any projects, construction, or contracting work being done at the building. On the morning of decedent’s accident, June Electrical directed decedent, its employee, to correct two items on a punch list from a contract that 47 East 34th and June Electrical had executed the prior year to correct outstanding items and totally complete the construction of the building. One of these items was to properly terminate the bus duct (a main trunk for electricity) in the roof bulkhead electrical room.   Cuevas accompanied decedent and his helper and unlocked the electrical room containing the bus duct. For this task, decedent planned to use an improvised foil cap and cardboard insulation. However, Cuevas left to get rubber insulation from a nearby hardware store, and allegedly told decedent not to start work until he returned and powered down the building's electricity. During Cuevas's absence, plaintiff alleges that decedent retrieved a 10-foot A-frame ladder from the boiler room and began work on the energized bus duct, about 15 to 20 feet above the floor. Within minutes, an arc explosion caused decedent to be electrocuted and thrown off the ladder. Despite his extensive injuries, decedent managed to walk down 36 flights to the ground floor, where he was taken by ambulance to a hospital. He remained hospitalized for months, undergoing extensive treatment for his burns and related sequelae, but died nine months later.   The trial court granted the motions of 47 East 34th and CIM and Bridgestreet for summary judgment dismissing plaintiff's Labor Law §§ 240(1) and 241(6) claims as against them, denied so much of 47 East 34th and CIM's motion, Bridgestreet's separate motion, and the cross-motion of June Electrical for summary judgment dismissing plaintiff's Labor Law § 200 and common-law negligence claims as against them, and denied so much of June Electrical's cross-motion seeking dismissal of the common-law indemnification and contribution claims as against it,   Labor Law § 240(1) (MAS) The First Department affirmed the trial court’s finding of an issue of fact as to whether CIM had any ownership interest in the building at the time of the accident. However, the Court reversed the trial court’s decision granting 47 East 34th's and CIM’s summary judgment and held issues of fact exist as to the manner in which decedent’s accident occurred. The Court noted that Cuevas was personally aware of decedent’s work history, which included working on energized wire circuitry “all the time” and despite allegedly warning decedent not to start working until he returned and powered down the building, Cuevas did not lock the door to the roof electrical room that invited just such an accident as happened. Cuevas also had post-accident conversations with decedent and plaintiff, where he admitted to plaintiff that decedent had to perform the bus duct work without shutting down the electricity.   The Court therefore found a material issue of fact as to whether the building’s electricity would actually have been turned off before decedent was to work on the bus duct; a reasonable factfinder could instead conclude, contrary to Cuevas’s testimony, that decedent had been compelled to perform work on the energized bus duct. Additionally, the Court deemed those conversations between Cuevas, decedent, and plaintiff in the hospital as not hearsay, but party admissions, particularly because Cuevas’s deposition testimony was inconsistent with his post-accident conversations with plaintiff, which the Court deemed as “tailored to totally fault [decedent] for his accident and absolve Bridgestreet, 47 East 34th, and CIM, his respective employers.”   Plaintiff also argued that defendants failed to provide decedent with a ladder or harness, in violation of Labor Law 240(1) and it is undisputed that he was not provided with a ladder, harness, or any other safety equipment. Not only did the Court find an issue of fact as whether the ladder’s purported inadequacy or the absence of additional safety devices was a proximate cause of decedent’s accident, the Court also found questions of fact as to whether the ladder failed to provide proper protection and whether decedent should have been provided with additional safety devices.   PRACTICE POINT: Hearsay is a statement, made by someone other than the declarant while testifying, offered in evidence for the truth of the matter asserted. An exception to hearsay is an admission by a party-opponent, as it is not hearsay. In this case, although plaintiff referred to the hearsay statements in opposition to defendants’ respective summary judgment motions, she raised a hearsay exception-based argument for the first time on appeal. Typically, new arguments raised on appeal are not considered, but the court considered it here because defendants also relied on it in support of their motions, which raised a triable issue of fact as whether those statements are accurate.   Labor Law § 241(6) (TPW) The First Department found material issues of fact as to whether decedent was the sole proximate cause of his accident. With respect to the Labor Law § 241(6) claim, Industrial Code § 23-1.13(b)(4) provides, “[n]o employer shall suffer or permit an employee to work in such proximity to any part of an electric power circuit that he may contact such circuit in the course of his work unless the employee is protected against electric shock by de-energizing the circuit and grounding it or by guarding such circuit by effective insulation or other means”. Based on the record on appeal, decedent was placed in the position of coming into contact with the live bus duct and, thus, the Labor Law § 241(6) claim against defendants should not have been dismissed.   Labor Law § 200 and Common-Law Negligence (ESB) The First Department also held issues of fact preclude summary judgment of plaintiff’s Labor Law § 200 and common-law negligence claims as to whether 47 East 34th or CIM had actual or constructive notice of the dangerous uncapped bus duct. With respect to the means and methods theory of liability, there is no indicate in the record that 47 East 34th and CIM, who were not on site at the time of the accident, directly supervised or controlled the means and methods of decedent’s work. By contrast, Cuevas, Bridgestreet’s resident manager, admittedly directed the means and methods of the work by instructing decedent not to use cardboard as a barrier between the cap and bus duct and to wait until he returned with a rubber barrier to commence the work.   Indemnity Issues in Labor Law (BFM) The First Department affirmed the trial court’s holding that June Electrical failed to establish its entitlement to summary judgment dismissing 47 East 34th and CIM's third-party common-law indemnification and contribution claims. June Electrical failed to submit admissible evidence eliminating all issues of fact as to whether decedent suffered a grave injury under Workers’ Compensation Law § 11. The Court further noted that during a Workers’ Compensation hearing, the parties had acknowledged that decedent had passed away as a result of his injuries.    
Tinti v Alpha Omega Bldg. & Consulting Corp. September 27, 2022 Appellate Division, First Department
  Plaintiff allegedly was injured when a 10-foot section of a 6-inch diameter hose used to pour concrete fell from 10 feet above and struck him. A certified incident report indicated that the hose had been placed on a wooden guardrail of the garage ramp above, where concrete was being poured, and that the hose fell when the guardrail collapsed under its weight. The trial court granted plaintiff's motion for summary judgment on his Labor Law § 240(1) claim as against defendant QPS.   Labor Law § 240(1) (MAS) The First Department unanimously affirmed the trial court’s decision because the hose fell due to it being positioned on a wooden guardrail which collapsed under the weight of the hose, and plaintiff also submitted an expert affidavit concluding that the hose had not been adequately secured for purposes of the undertaking.   PRACTICE POINT: Since the record demonstrated that the falling object, the hose, was not adequately secured for the purpose of the injury-producing work, as required under the statute, plaintiff was entitled to summary judgment.    
Yocum v United States Tennis Assn. Inc. September 27, 2022 Appellate Division, First Department
  Plaintiff allegedly fell from a sloped roof and testified there was no appropriate place to tie off on the roof. The trial court denied plaintiffs' motion for summary judgment on their Labor Law §§ 240(1) and 241(6) claims and denied plaintiffs' cross-motion for leave to renew and reargue their motion as to the Labor Law § 241(6) claim.   Labor Law § 240(1) (MAS) The First Department unanimously reversed the trial court and granted plaintiff’s motion because there was no appropriate place to tie off on the sloped roof from which plaintiff fell. In opposition, the Court held defendant failed to raise a triable issue of fact as to whether plaintiff was the sole proximate cause of his injuries. Defendants’ contention that a fall protection system had been installed on the roof before the date of the accident was based on unauthenticated documents and vague testimony of individuals without personal knowledge. Even if the system had been fully installed, the Court found there was no evidence that plaintiff was trained in its use.   PRACTICE POINT: To prove the sole proximate cause defense, a defendant must show that (1) adequate safety devices were available to plaintiff; (2) he or she knew both the safety devices were available and were expected to be used; (3) chose for no good reason not to do so; and (4) would not have been injured had they not made that choice. Here, defendant could not establish the second element that plaintiff was trained on the fall protection system and knew how to use it.   Labor Law § 241(6) (TPW) Considering the First Department’s decision above, it declined to address plaintiff’s Labor Law § 241(6) claim.    
Fuczynski v 144 Div., LLC September 14, 2022 Appellate Division, Second Department
  Plaintiff was employed as a carpenter and laborer by nonparty First Quality, which was performing work on a commercial renovation project at a building owned by defendant. Plaintiff testified at his deposition that on March 7, 2016, his supervisor directed him to install sheetrock on a ceiling of the building's first floor. According to plaintiff, while disconnecting a lighting fixture from the ceiling, he suffered an electric shock and fell from a six-foot tall Baker scaffold, which lacked guardrails, and was injured. The trial court denied plaintiff's motion for leave to serve and file a late motion for summary judgment and, for summary judgment on the Labor Law §§ 240(1) and 241(6) claims.   Labor Law § 240(1) (MAS) The Second Department reversed and held the trial court improvidently exercised its discretion in denying that branch of plaintiff’s motion which sought leave to serve and file a late motion for summary judgment. Plaintiff argued that good cause existed for the delay in filing their motion because depositions had not been conducted at the time the note of issue was filed, in addition to the need to secure responses to the plaintiff’s post-deposition demands. The Court disagreed with the trial court’s finding that the post-deposition discovery sought by plaintiff was not essential to his motion for summary judgment. The Court found that the discovery sought related to testimony indicating that plaintiff may have been engaged in unauthorized work at the time of the accident, which may be a defense to the Labor Law claim.   Accordingly, the Court held the trial court should have granted that branch of plaintiff’s motion for leave to serve and file a late motion for summary judgment, and the case was remitted to the trial court for a determination on the merits of those branches of plaintiff’s motion which were for summary judgment on his Labor Law 240(1) and 241(6) claim.   PRACTICE POINT: A party may not move for summary judgment after the deadline to do so has expired, “except with leave of court on good cause shown” (CPLR 3212[a]). As a result, a court may not consider a late motion for summary judgment unless the moving party offers “a satisfactory explanation for the untimeliness – rather than simply permitting meritorious, nonprejudicial filings, however tardy”.  While significant outstanding discovery may, in certain circumstances, constitute good cause for a delay in making a summary judgment motion, the movant must establish the discovery was “essential to its motion”. Here, the Court held the discovery sought by plaintiff was essential to his motion, overruling the finding by the trial court.    
Lima v HY 38 Owner, LLC September 14, 2022 Appellate Division, Second Department
  Plaintiff was allegedly injured when he was struck by a section of a caisson pipe that was being cut with a blow torch by a coworker. Plaintiff testified at his deposition that a strap was tied around the pipe and connected to the bucket of a backhoe excavator to prevent the pipe from falling to the ground after it was cut. The strap was tied “very tight[ly]” or “tense[ly].” As his coworker cut the pipe, the pipe “suddenly” sprang up several feet into the air and struck him. The trial court denied plaintiffs' motion for summary judgment on the Labor Law §§ 240(1) and 241(6) claims and granted defendants' cross-motion for summary judgment dismissing the § 241(6) claim. The trial court also denied defendants’ cross-motion for summary judgment dismissing the § 240(1) claims and dismissing the Labor Law § 200 and common-law negligence claims against Monadnock.   Labor Law § 240(1) (MAS) The Second Department affirmed the trial court’s decision because neither plaintiffs nor defendants established their prima facie entitlement to judgment as a matter of law with respect to the Labor Law § 240(1) claim. Triable issues of fact exist as to how the alleged accident occurred, including whether plaintiff’s injuries resulted from the type of hazard contemplated under the statute, or whether plaintiff’s injuries were caused when the pipe was propelled upward by the sudden release in the tension of the strap and, thus, were “not the direct consequence of the application of the force of gravity to an objection or person”.   PRACTICE POINT: To recover under Labor Law § 240(1), the hazard to which plaintiff was exposed must have been one “directly flowing the application of the force of gravity to an object or person” (Ross v Curtis-Palmer Hydro. Co., 81 NY2d 494 [1993]). In cases such as this where neither side can demonstrate exactly how the accident occurred, neither side can meet its initial burden of establishing that the injury was or was not caused by the direct consequence of the application of the force of gravity to an object or person.    
Smith v City of New York September 21, 2022 Appellate Division, Second Department
  Plaintiff was a site safety inspector for construction work performed by certain contractors at the New York City Tallman Island Wastewater Treatment Plant located in College Point, Queens. As plaintiff walked back to her vehicle one morning after a routine safety inspection at the facility, she allegedly slipped on black ice that was present on the access road.   The trial court denied the City’s motion for summary judgment dismissing the negligence action and all crossclaims insofar as asserted against it, granted the separate motions of Malcolm and WDF for summary judgment dismissing the amended complaint and all crossclaims asserted against each of them, and granted Picone’s motion for summary judgment dismissing the amended complaint, all crossclaims, the third-party complaint, and the amended second third-party complaint asserted against it. The trial court also granted Prinie’s motion for summary judgment dismissing the negligence action, granted the motion of WDF, which was for summary judgment dismissing the negligence claim against it, and granted Picone’s motion for summary judgment dismissing the Labor Law 241(6) claim against it.     Labor Law § 241(6) (TPW) This appeal focused on prior notification laws as prerequisites for litigation, and the Second Department affirmed that portion of the trial court’s order granting those branches of defendants’ separate motions for summary judgment dismissing the Labor Law § 241(6) claim as the only Industrial Code provision relied upon by plaintiff was not applicable to the facts of this case.   Labor Law § 200 and Common-Law Negligence (ESB) The Second Department reversed the trial court and granted the City’s motion to dismiss the negligence claim because there is no evidence that the City created the allegedly dangerous condition. The Court accepted the City’s contention that an expert affidavit submitted by plaintiff was conclusory, speculative, and insufficient to raise a triable issue of fact. In opposition, the Court held that plaintiff failed to raise an issue of fact as to whether the City affirmatively created the allegedly dangerous condition.   Indemnity Issues in Labor Law (BFM) Having determined the City was entitled to summary judgment dismissing plaintiff’s negligence cause of action against it, the Second Department reversed the trial court and dismissed all crossclaims asserted against the City. In so holding, the Court noted that plaintiff failed to raise a triable issue of fact as to whether the City affirmatively created the allegedly dangerous condition, and that plaintiff’s expert’s affidavit was speculative and conclusory.    
Matter of Joseph v City of New York September 28, 2022 Appellate Division, Second Department
  Petitioner, a laborer, was allegedly injured when he tripped or slipped on stairs while performing construction work at the South Beach Psychiatric Center in Staten Island. A timely notice of claim dated June 15, 2019, was served on the State of New York and the New York State Office of Mental Health, which alleged that the State was negligent in causing construction debris to exist on the stairwell and violated certain provisions of the Labor Law. Thereafter, on July 30, 2020, petitioner commenced a second proceeding pursuant to General Municipal Law § 50-e(5) for leave to serve a late notice of claim on, DASNY. The trial court denied the petition to serve a late notice of claim on the City and DASNY.   Labor Law § 241(6) (TPW) The Second Department reversed the trial court’s decision denying that branch of the petition which was for leave to serve a late notice of claim on DASNY. Petitioner’s assertion that the COVID-19 pandemic hindered his ability to obtain documentation identifying the proper municipal entities did not, under the circumstances of this case, constitute a reasonable excuse. However, petitioner’s submissions demonstrated that DASNY’s insurers had actual notice of the essential facts constituting the claim within 90 days of the accident. Given that DASNY’s insurers had timely, actual notice, petitioner further satisfied his initial burden of presenting “some evidence or plausible argument” that DASNY would not be substantially prejudiced if the late notice is allowed. In response, the Court held DASNY failed to set forth “a particularized evidentiary showing” that it will be substantially prejudiced. Accordingly, weighing the appropriate factors, the Court held the trial court should have granted that branch of the petition which was for leave to serve a late notice of claim on DASNY.   However, the Court denied that branch of the petition which was for leave to serve a late notice of claim on the City. Petitioner’s contention that the City may have acquired knowledge of petitioner’s accident because it owned the premises where the accident occurred is speculative and insufficient to establish actual knowledge. Petitioner’s additional contention that the City had actual notice because it affirmatively caused or created the dangerous condition on the stairs is improperly raised for the first time on appeal. In any event, even if the City had affirmatively caused or created the dangerous condition, the Court held this would not establish that it had actual notice of petitioner’s accident itself. The Court further declined to consider the additional materials that were improperly submitted to the trial by petitioner for the first time with his reply papers.  
 New York Industrial Code Regulations (EDA)
12 NYCRR 23-1.24(a)(2)(i) Crawling board construction. Crawling boards shall be at least 10 inches in width and one inch in thickness. Each crawling board shall be provided with cleats which are at least one and one-half inches in width by one inch in thickness. Such cleats shall be spaced at equal intervals across the full width of the board and shall be firmly nailed. Cleat nails shall be driven through and clinched or shall be of the screw type. Crawling boards shall extend from the ridge poles to the eaves when used in connection with roof construction, repair or maintenance. Regulation § 23–1.24(a)(2)(i), specifying the specifications for crawling boards, is likely sufficiently specific to support a Labor Law § 241(6) claim.
The Court of Appeals found that the Supreme Court properly granted plaintiff's motion for partial summary judgment as to liability under Labor Law § 240(1), finding that “in the instant case, involving as it does a sloped roof, this court believes that the risk of slipping and falling while working upon that slope is more certainly related to the direct application of gravity, pulling the worker from the elevation differential between the ridge of the roof to its eave, than if he were merely standing on a flat roof. It is for this reason that roof brackets and/or toe boards (crawling boards), etc., are required by 12 NYCRR 23–1.24(a) and (b).” (175 Misc.2d 698, 700, 669 N.Y.S.2d 496 [1998].)  
Striegel v Hillcrest Hgts. Dev. Corp., 100 NY2d 974, 976-77 [2003]
Labor Law Pointers   Editor David R. Adams Associate Editor Eric S. Bernhardt Associate Editor Brian F. Mark Associate Editor Timothy P. Welch Associate Editor Marc A. Schulz Associate Editor Eric D. Andrew Labor Law Team
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