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Volume XII, No. 6
Wednesday, May 3, 2023
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 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.
The hot topic of the day is the proposed legislation to, again, address the Grieving Families Act, which was overwhelmingly passed by both houses of the Legislature, but vetoed by the Governor. This newly proposed bill, dated yesterday, defines the pool of valid plaintiffs with a clearer definition of those who may seek to be considered, but the jury still would be tasked with determining who is sufficiently close enough to be compensated. The Statute of Limitations would be expanded from two years to three years, and retroactivity remains. The damages recoverable remain the same as the vetoed bill, including “loss of love, society, protection, comfort, companionship, and consortium resulting from the decedent's death” thus greatly increasing the types of damages for which compensation is available.
Labor Law Attorney Eric Andrew addresses the proposed bill here: The Resurrection of the Grieving Families Act: Another Attempt to Revamp New York’s Wrongful Death Statute.
With this potential vast enlargement of not only the pool of individuals, but also the damages for which compensation can be obtained, it seems timely to remind our subscribers of our CAT Team, or Catastrophic Injury Team, specifically staffed statewide with experienced attorneys and support, to not only defend these high exposure cases but to explore all potential coverage and risk-transfer opportunities. Just click on the link above for the full details.
In our first photo of the week, you will notice a couple of attorneys, who are volunteering for Habitat for Humanity, standing on ladders, installing vinyl siding on a house, destined to be assembled on-site, for a deserving family to call home. Your editor, along with Steve Peiper, coverage lawyer extraordinaire and Labor Law aficionado, had a discussion while engaged in this process about the application of § 240(1) to this situation. We were volunteering for Habitat for Humanity but, shockingly, were answering our phones and responding to emails from our clients during the day. Were we “persons so employed” and thus covered by the protections of § 240(1)?
So, the answer is that § 240(1) would not apply because, while we were working at the time as attorneys, and thus employed in that capacity, we were not being paid for the construction work we were engaged in at the time we would have sustained an injury caused by an elevation differential or gravity. Therefore we were not “so employed” in construction. See Fuller v Spiesz. I would like to point out that we enjoyed our time with Habitat for Humanity, and that we did a damn-fine job siding the house. Look at how nicely the j-channel and siding were installed around those windows! But please, don’t ask how long it took us.
For our next offering we have a situation where a host on a QVC program is seeking to sell ladders – 12 ½ foot telescoping ladders to be exact – and decides to demonstrate the ladders’ extreme stability by cleaning a window on the set. The host does not work for the company who owns the set, nor does he work for QVC, but rather, his company was hired specifically to sell these ladders. § 240(1)?
Hopefully no one had forgotten the outcome above. While the plaintiff was working at the time of the fall, he was not employed to do cleaning work, an enumerated activity, but was rather employed as a salesperson and, thus, is not a valid plaintiff. In all other aspects, he would have qualified, by the way. The property owner would be a valid defendant; the activity was cleaning (commercial, not residential in nature); and the injury occurred due to the effects of gravity and a height differential.
The final video offering of the month is a quiz: Please count the activities that could be the basis of a § 240(1) claim, assuming that all individuals are “persons so employed”. There will be prizes.
Send me your answers for valuable prizes*. Have a great month!
*DISCLAIMER: Prizes have zero (0) actual value.
That is all we have for you this month. As always, please feel free to reach out to us with any questions Labor Law or Risk Transfer related.
David
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: www.hurwitzfine.com
Labor Law Pointers is published the first Wednesday of each month. If you know of others who may wish to subscribe to this free publication, please feel free to forward it. If you wish to subscribe or unsubscribe, please send an e-mail to [email protected] or call the Editor/Labor Law Team Leader David R. Adams directly at (716) 849-8916.
Don’t forget to subscribe to our other publications:
Coverage Pointers: This twice-monthly electronic newsletter summarizes important insurance law decisions from appellate courts in New York State with the occasional snapshot across borders. Coverage Pointers, the electronic newsletter that started it all, continues to offer guaranteed publication every other Friday, and a read-at-a-glance summary of important decisions as they happen. Contact Dan Kohane at [email protected] to subscribe.
Medical & Nursing Home Liability Pointers: Medical & Nursing Home Liability Pointers provides the latest news, developments, and analysis of recent court decisions impacting the medical and long-term care communities. Contact Chris Potenza at [email protected] to subscribe.
Premises Pointers: This monthly electronic newsletter covers current cases, trends and developments involving premises liability and general litigation. Contact Jody Briandi at [email protected] to subscribe.
Products Liability Pointers: This monthly newsletter covers all areas of products liability litigation, including negligence, strict products liability, breach of warranty claims, medical device litigation, toxic and mass torts, regulatory framework and governmental agencies. Contact Chris Potenza at [email protected] to subscribe.
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April 18, 2023
Appellate Division, First Department
Plaintiff allegedly fell from an elevated plywood platform that ran from an exterior hoist of a building into a mechanical room. The trial court granted defendants' motion for summary judgment dismissing the Labor Law § 240(1) claim, denied plaintiff's motion for summary judgment on the Labor Law § 241(6) claim predicated on a violation of Industrial Code (12 NYCRR) § 23-5.1, but granted plaintiff's motion based on a violation of Industrial Code § 23-1.22(b)(2), and struck defendants' affirmative defense of comparative fault.
 Labor Law § 240(1) (MAS)
The First Department affirmed the trial court’s decision to grant defendants’ motion dismissing this claim because, under the circumstances, a fall of 10 inches was not a physically significant height differential to trigger the protection of Labor Law § 240(1).
PRACTICE POINT: The First Department has now identified one specific distance (10 inches), which is not a physically significant height elevation differential, and from which a fall does not warrant the extraordinary protections of the statute.
 Labor Law § 241(6) (TPW)
The First Department unanimously modified the underlying Order arising from the parties’ competing motions for summary judgment on the issue of Labor Law 241(6) liability. The Court reversed the grant of that portion of plaintiff’s summary judgment predicated on 12 NYCRR 23-1.22(b)(2) as the record failed to demonstrate that the plywood platform was a runway or ramp intended for the use of "persons only". However, the Court affirmed the denial of plaintiff's motion predicated on 12 NYCRR 23-5.1 as the platform from which plaintiff fell was used by workers to transport materials from the hoist to the mechanical room and was not being used as the functional equivalent of a scaffold.
Plaintiff allegedly fell from the scaffold and was injured. The trial court denied plaintiff's motion for partial summary judgment on his Labor Law § 240(1) claim and granted defendants' cross motion for summary judgment dismissing the claim.
Labor Law § 240(1) (MAS)
The First Department unanimously affirmed the trial court’s decision, as plaintiff established little other than he fell from the scaffold, which, in and of itself, does not establish a claim under Labor Law § 240(1). Liability under the statute requires both a violation of the statute and causation. Defendants established that the scaffold was equipped with proper guardrails, which provided an adequate safety device, and was undamaged after the alleged incident, so that there was no violation of § 240(1). Moreover, plaintiff was unable to recall how he fell from the scaffold and could provide no evidence that his fall was caused by a lack of a safety device; therefore, any finding of a violation would be purely speculative.
PRACTICE POINT: For an injured worker to obtain partial summary judgment under Labor Law 240(1), he or she must demonstrate that the statute was violated, and that the violation was a proximate cause of his or her injuries. Here, not only was the plaintiff unable to meet his burden, but the defendants’ proof affirmatively established there was no violation of the statute.
Walton Realty owned the building, where plaintiff was installing 30 feet of pipes and electrical lines in the building, from two commercial-grade refrigeration units inside the tenant's space, to compressors outside, when he allegedly fell from two unsecured A-frame ladders. The trial court granted plaintiff’s motion for partial summary judgment under § 240(1) and denied Walton Realty’s motion for summary judgment dismissing that claim.
Labor Law § 240(1) (MAS)
The First Department unanimously affirmed, as plaintiff established his injuries were proximately caused by a violation of the statute, as it was undisputed that the only safety devices supplied to him – two unsecured A-frame ladders – failed to afford him adequate protection to perform the installation of the refrigeration unites while at an elevation. In opposition, the Court held that Walton Realty failed to raise an issue of fact as to whether plaintiff’s conduct was the sole proximate cause of his injuries.
PRACTICE POINT: Because the injured worker was provided with two unsecured A-frame ladders, that did not prevent him from falling and being injured, he was not provided adequate safety devices, and the property owner could not avail itself of the sole proximate cause defense.
SLG 100 entered into a full-service maintenance contract with Marcato to maintain and repair the elevators at the premises. Plaintiff, a Kleinknecht employee, allegedly was struck by a horizontally closing elevator door at the premises that was manually closed by an elevator operator, although the operator denied operating the door at the time of the incident. Conflicting testimony and documentary evidence indicated there was a different elevator operator at the time of incident, who also denied closing the door prematurely. At the time of the incident, plaintiff and the second operator were employed by nonparty SL Green Management.
The trial court granted the motion of SLG 100, the cross-motion of L&K Partners, and of P.S. Marcato Elevator Co. (collectively, defendants) for summary judgment dismissing the second amended complaint, and denied plaintiff's cross-motion for leave to file and serve a third supplemental summons and amended complaint to name SLGM Corp. and SLGM LLC as defendants and dismissing the second amended complaint; dismissing as moot SLG 100’s unpled claim for contractual indemnification against L&K, its crossclaims and third-party claims for contractual indemnification against PS Marcato, and its third-party claim for contractual indemnification against Kleinknecht Electric Company.; and dismissing as moot L&K's third-party cross claim for contractual indemnification against Kleinknecht.
 Indemnity Issues in Labor Law (BFM)
The Court affirmed the trial court’s denial of SLG 100’s unpleaded contractual indemnification claim against L&K. The Court also determined that SLG 100 was properly denied summary judgement on its contractual indemnification claim against Kleinknecht. SLG 100's contracts with PS Marcato and Kleinknecht require that SLG 100 be indemnified from any claims “arising out of,” or “relating to . . . acts” or “omissions” connected to their work for SLG 100, in the event that PS Marcato and Kleinknecht were negligent with respect to plaintiff's accident. As there was no evidence that Kleinknecht was negligent, the indemnification claim against it was properly dismissed. Because the plaintiff's negligence claim against Marcato was reinstated, the Court held that SLG 100's cross claim must also be reinstated and that SLG 100 was entitled to conditional summary judgment that it must be indemnified if Marcato is later judged to be negligent.
The Court determined that L&K was entitled to summary judgment on its contractual indemnification claim against Kleinknecht, noting that the indemnification clause in the subcontractor vendor agreement between L&K and Kleinknecht states that “[Kleinknecht] agrees to indemnify . . . [L&K] from any and all claims . . . related to . . . personal injuries . . . brought against [L&K] . . . arising out of or in connection with or as a result or consequence of the performance of [Kleinknecht's] Work . . . whether or not caused in whole or in part by [Kleinknecht] . . .” Notably, indemnification agreements with a scope-or performance-of-the-work clause are broad and will be triggered solely by virtue of an accident occurring in the course of the indemnitor's work. While there was no evidence that any negligence on Kleinknecht's part contributed to plaintiff's accident, its indemnify obligation under the agreement was triggered by the fact that the accident arose from plaintiff's performance of his work in the course of his employment by Kleinknecht.
Plaintiff allegedly was injured when he fell from a ladder, while delivering masonry supplies, on a construction site where his employer had been hired as a subcontractor. Bergen Beach was the general contractor and owner of the premises. The trial court denied plaintiff's motion for summary judgment under Labor Law § 240(1).
Labor Law § 240(1) (MAS)
The Second Department affirmed the trial court’s denial of plaintiff’s motion because his own submissions demonstrate triable issues of fact as to whether the statute was violated and whether such a violation was a proximate cause of his injuries.
PRACTICE POINT: The fact that the injured worker fell from a ladder, standing alone, is insufficient to establish that proper protection was not provided, and whether a particular safety device provided proper protection is generally a question of fact for a jury.
A building under construction in Queens collapsed, allegedly under the weight of construction materials stored on the roof. Plaintiff commenced an action for personal injuries he sustained in the collapse. Among the defendants named in the amended complaint were Cindy Koumantaros, the owner of the property; Ideal, the general contractor; and CDW, a subcontractor. Also named were the Argyros defendants, the owners of a neighboring property, which allegedly was part of the same construction site, and JSK, which constructed a sidewalk shed as part of the work. Plaintiff Baljinder Singh commenced a separate action for personal injuries he sustained in the building collapse against Ideal, the Argyros defendants, and Koumantaros. CDW and JSK were not named as defendants in that action. Both plaintiffs asserted causes of action alleging violations of Labor Law §§ 240(1), 241(6), 200 and common-law negligence. Neither plaintiff alleged that he suffered a grave injury as defined under the Workers' Compensation Law. The trial court consolidated the actions for all purposes.
Around the time of consolidation, in the Velazquez-Guadalupe action, Ideal commenced a third-party action against subcontractors J. United and the Hephaistos entities, alleging that one or all of them were responsible for placing the materials on the roof that caused it to collapse. In the Velazquez-Guadalupe action, CDW, JSK, Ideal, Koumantaros, and the Argyros defendants all asserted crossclaims against one another for contribution and common-law indemnification, among other things. Koumantaros additionally asserted crossclaims for contractual indemnification and alleging breach of contract for failure to procure insurance.
Plaintiffs also pursued separate claims before the WCB. After a hearing on Velazquez-Guadalupe's claim, the WCB found an "employer/employee relationship" existed between Velazquez-Guadalupe and CDW on the date of the accident, contradicting Velazquez-Guadalupe's allegations in his complaint, amended complaint, and several of his bills of particulars that he, actually, was employed by J. United on the date of the accident. The WCB also awarded Singh compensation for his injuries, although it further determined that he was employed by J. United, which was uninsured on the date of the accident.
The trial court denied the motion of JSK for summary judgment dismissing the amended complaint and all crossclaims against it without prejudice to renew upon the completion of discovery, denied CDW’s motion for summary judgment dismissing the crossclaims of Ideal, JSK, the Argyros defendants, and Koumantaros for contribution and common-law indemnification, and granted the cross-motion of the Arygos defendants for leave to amend their answer to assert a cross-claim against CDW alleging breach of contract for failure to procure insurance.
Indemnity Issues in Labor Law (BFM)
The Second Department noted that Velazquez-Guadalupe did not suffer a grave injury within the meaning of Workers’ Compensation Law § 11 and that there was no allegation in any of the pleadings that CDW expressly agreed in writing to contribute to or indemnify any party. CDW established its entitlement to judgment as a matter of law dismissing the contribution and common-law indemnification crossclaims asserted against it by demonstrating that the WCB determined that CDW was Velazquez-Guadalupe's employer and that Velazquez-Guadalupe received benefits from CDW's insurance carrier. In opposition, Koumantaros, Ideal, the Argyros defendants, and the Hephaistos entities failed to raise a triable issue of fact. The Court further noted that controversies regarding the applicability of the Workers' Compensation Law rest within the primary jurisdiction of the Workers' Compensation Board, including issues as to the existence of an employer-employee relationship. Accordingly, evidence concerning whether CDW could invoke the common-law doctrine of collateral estoppel was irrelevant since CDW's entitlement to dismissal of the contribution and common-law indemnification crossclaims asserted against it by “any third person” arises under the Workers' Compensation Law.
Finding no evidence of surprise or prejudice, the Court affirmed the trial court’s granting leave to the Argyros defendants to amend their answer to assert a crossclaim against CDW alleging breach of an oral agreement to procure insurance as an “agreement to procure insurance is not an agreement to indemnify or hold harmless,” which would be barred under the Workers’ Compensation Law. Contrary to CDW's contention, an agreement to procure insurance may be enforceable even if it is not in writing.
Plaintiff allegedly was injured when he received an electric shock from an exposed live wire while performing remodeling work at a grocery store. The property was owned by 1438 South Park Avenue and leased to Tops Markets, who, together, commenced a third-party action against plaintiff's employer, IPL, seeking contractual indemnification. The trial court granted defendants' motion and IPL's cross-motion for summary judgment on the Labor Law §§ 240(1) and 200 claims; denied defendants' motion and IPL's cross-motion with respect to the § 241(6) claim; denied defendants' motion with respect to their third-party complaint; denied IPL's cross-motion with respect to the third-party complaint; and granted plaintiff's cross-motion in part, determining that defendants violated the Industrial Code provisions but that issues of fact exist regarding proximate cause and comparative negligence.
Labor Law § 241(6) (TPW)
The Fourth Department unanimously affirmed that portion of the underlying Order as it applied to the Labor Law § 241 (6) claim. Plaintiffs’ claims were premised upon defendants' alleged violations of two provisions of 12 NYCRR 23.-1.13(b). Defendants did not dispute that they violated those provisions of the Industrial Code or that 12 NYCRR 23.-1.13(b) was sufficiently specific to support a section 241 (6) claim, however Defendants argued plaintiff was negligent in working on the live wire without contacting his supervisor or shutting off the power to that line and that his negligence was the sole proximate cause of his injuries. The Appellate Division rejected that contention noting that there may be more than one proximate cause of an injury, and that questions of proximate cause are generally for the jury to resolve. The Court continued that even assuming plaintiff was negligent in his handling of the wire, defendants failed to establish as a matter of law that their violations of the Industrial Code were not "a substantial factor in bringing about the injury".
 Labor Law § 200 and Common-Law Negligence (ESB)
The Fourth Department modified the trial court’s decision by reversing the order granting summary judgment as to common-law negligence and § 200. It noted that those claims were based on an alleged dangerous condition at the work site (i.e., an exposed live electrical wire) and not the method and manner of plaintiff’s work. There was no dispute that the wire constituted a dangerous condition. However, the Court held that defendant and third-party defendant failed to establish, as a matter of law, that defendants did not create or have actual or constructive notice of the dangerous condition.
Indemnity Issues in Labor Law (BFM)
The Fourth Department affirmed the trial court’s denial of defendants’ motion for summary judgment on their third-party complaint seeking contractual indemnification. The contract between Tops and IPL, which included an indemnification clause, was signed two months after plaintiff's accident. The Court held that defendants failed to establish that Tops and IPL intended the indemnification clause of their contract to apply retroactively. In support of their motion, defendants submitted the contract, which does not state that it is retroactive, along with the deposition testimony of various witnesses, none of whom testified unequivocally about the intent of Tops and IPL. Accordingly, the Court found questions of fact as to whether Tops and IPL intended the clause to apply retroactively.
Plaintiff allegedly was injured while working on a construction project on property owned by defendant. After plaintiff's first lumbar spine surgery, defendant expressly waived its right to conduct an IME of that body part. At the time it made the waiver, defendant knew that plaintiff might undergo another surgery at the direction of his doctor. The trial court limited the scope of the IME of plaintiff's lumbar spine to the second spinal surgery and its causal relationship to the underlying accident.
Labor Law § 240(1) (MAS)
The Fourth Department unanimously affirmed the trial court’s decision. This is not a situation in which defendant inadvertently waived the IME of the spine or was requesting reexamination of a body part that had already been the subject of an IME. Despite defendant’s waiver, the trial court allowed defendant to conduct an IME of plaintiff’s spine, only limiting the scope of the exam to the second spinal surgery and its causal relationship to the accident.
The Court also dismissed defendant’s appeal of the trial court’s order insofar as it precluded defendant’s expert from opining at trial about plaintiff’s first spinal surgery and its causal relationship to the accident. The motion did not seek to preclude any trial testimony offered by defendant, and the court’s statement about the testimony defendant would be prohibited from offering represented nothing more than an advisory opinion.
PRACTICE POINT: Trial courts have broad discretion in supervising disclosure, and, absent a clear abuse of that discretion, a trial court’s exercise of such authority should not be disturbed. Here, the Fourth Department could not say that, in fashioning a compromise that limited the scope of the IME to the second spinal surgery and its causal relationship to the accident, the trial court abused its broad discretion in supervising disclosure.
Plaintiff allegedly was injured while working on a sewer replacement project, pursuant to a contract executed between Niagara Falls Water Board and plaintiff's employer. At the time of the accident, plaintiff was using an excavator to disassemble a manhole shield. Before plaintiff began to remove the first side panel of the shield, his supervisor removed securing pins from both sides of several spreader bars, contrary to normal procedure. As plaintiff began to separate the first side panel, one of the unsecured spreader bars fell into the cab of the excavator. The trial court denied the motion of Niagara Falls Water Board, Niagara Falls Public Water Authority and Niagara Mohawk Power Corporation, doing business as National Grid, for summary judgment dismissing plaintiffs' amended complaint against them.
Labor Law § 240(1) (MAS)
The Fourth Department affirmed the trial court’s decision to grant plaintiffs summary judgment. Plaintiffs established that defendant was an “owner” for purposes of Labor Law § 240(1) and that this case involved an elevation risk regarding the spreader bars, which were elevated above ground at the time of the accident as “required securing for purposes of the undertaking.” Plaintiff further established that the spreader bar fell at a time when neither plaintiff nor his supervisor wanted it to fall. Moreover, plaintiffs demonstrated that defendant failed to ensure that plaintiff knew both that safety devices were available and that he was expected to use them.
PRACTICE POINT: An injured worker seeking to recover for injuries from a falling object under Labor Law § 240(1) must establish both (1) that the object was being hoisted or secured, or that it required securing for the purposes of the undertaking; and (2) that the object fell because of the absence of inadequacy of a safety device to guard against a risk involving the application of the force of gravity over a physically significant elevation differential. Here, plaintiff demonstrated that the spreader bars were elevated above ground at the time of the accident and required securing, since the harm in this case flowed directly from the application of the force of gravity to the spreader bars.
Labor Law § 241(6) (TPW)
Given the determination by the Fourth Department on the issue of the Board's liability under Labor Law § 240 (1), the Court concluded that the Board’s contentions regarding plaintiffs' Labor Law § 241 (6) claim were academic. However, it also held that the lower court erred in denying NiMo's motion with respect to the Labor Law § 241 (6) claim as it was based on the alleged violation of 12 NYCRR 23-4.2 (k) which is not sufficiently specific to support a Labor Law § 241 (6) claim. As for the alleged violation of 12 NYCRR 23-9.4 (e) (1) and (2) Defendants did not dispute that those regulations are sufficiently specific, but the Court concluded that the moving defendants failed to establish as a matter of law that NiMo did not violate those regulations or that any alleged violation was not a proximate cause of plaintiff's injuries.
 New York Industrial Code Regulations (EDA)
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Regulation § 23–1.24(d)(1)(ii), Hot roofing material transporters, also known as hot luggers.
Closed containers or devices used for transporting molten roofing materials from fill stations to the application areas on roofs shall be equipped with at least the following safety features in order to minimize hazards to persons caused by blowbacks of the molten roofing materials:
(1) Existing transporters.
On or before January 1, 1973, every existing transporter shall be equipped with the following safety devices:
(ii) On top of every such transporter remote from the fill pipe there shall be installed an automatic venting device designed to release any accumulation of gas pressure. Such venting device shall be inspected daily to assure proper operation.
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Regulation § 23–1.24(d) is sufficiently specific to support a Labor Law § 241(6) cause of action (Rudolph v Hofstra University, 225 AD2d 680, 640 NYS2d 126 [2d Dept. 1996]).
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§ 23–1.24(d) does not prohibit the use of open bucket of hot tar and is therefore inapplicable to accident involving hot-tar container with no lid or cover (Castillo v Starrett City, Inc., 4 AD3d 320, 772 NYS2d 74 [2d Dept. 2004]); inapplicable where plaintiff carrying hot tar in an open bucket, even though it may be an inherently dangerous activity (Stasierowski v Conbow Corp., 258 AD2d 914, 685 NYS2d 545 [4th Dept. 1999]).
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Tallchief v Jemco Roofing, 217 AD2d 915, 629 NYS2d 603 (4th Dept 1995) (issue of fact as to whether § 23-1.24(d) was violated where plaintiff was injured when end of flexible pipe came out of hot lugger and sprayed hot tar on plaintiff).
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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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