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Volume XV, No. 10
Wednesday, September 2, 2026
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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 beginning of September always means that summer is winding down, and that the courts will pick back up soon. For me it is usually time to make plans to get the boat out of the water, but this year it is time to prep for trial, and thus my note may seem a bit short today.
This month, our monthly Labor Law Case of the Month features, Cano v. 57-51 57th Rd., LLC.
This session will examine who qualifies as an “owner” for purposes of liability under Labor Law § 240(1), with a particular focus on when a lessee of property may be considered a proper defendant. I will discuss the degree of control over the work necessary to establish owner status, including contractual authority as well as actual supervision, direction, or control over the injury-producing work.
The program will also explore how the Appellate Divisions approach these issues differently and provide practical guidance for evaluating owner status and potential liability in Labor Law claims.
For more information and to register, click here.
We just completed our attorney development day, and our Labor Law team put together a Labor Law Jeopardy, complete with the required theme song. We had a blast! Many thanks to Ashley for putting it all together. I would like to point out that there was obviously cheating involved and that my team would have won in a fair contest. The prize, a month off from writing for Labor Law Pointers was well appreciated.
On top of that we had our Hurwitz Fine summer party and I was asked (told) to take a group picture. As I took the picture, see below, it was pointed out that I was on a tall stool right at the edge of a balcony and people below were wondering if I fell, if it could be a § 240(1) case. Please look at the photos below and decide for yourself.
I can tell you all that my wife, also an attorney with some background previously in handling Labor Law cases, is convinced that if I keep on climbing ladders, and stools, that I will eventually fall. In that case, she has pointed out, Labor Law Pointers will be entered as Exhibit 1, as proof supporting the sole proximate cause defense. If the fall is bad enough, I am convinced that my tomb stone will read, “he knew better but did not listen.”
Anyway, the party was very fun and Labor Law Jeopardy was great. Enjoy the rest of the summer and we will see you next month.
By the way, I think I was completely safe up there.
-David
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]
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 Liz Midgley at [email protected] to subscribe.
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Plaintiff was working as a carpentry laborer on a renovation when he slipped or tripped on a crack in a stone step as he descended the building's front exterior staircase. Plaintiff used the building's front staircase to bring debris to a curbside refuse container as per his foreman's instructions. At the time of the incident, plaintiff was carrying two bags of demolition debris that hung over his right shoulder and weighed approximately 30 pounds, while in his left hand he carried a bucket of debris that weighed between 10 to 15 pounds. Plaintiff testified that although there was another route out of the building through the basement's garage door, that area was full of debris. The Supreme Court granted the separate motions of defendants USM Asset Trust Series-7 and Penrith URF, LLC (collectively, the owners), defendant/third-party plaintiff EmpireHD, Inc., and third-party defendant Victorio's Contracting, Inc. for summary judgment dismissing plaintiff's Labor Law §§ 240(1) and 241(6) claims; denied the owners' and EmpireHD's motions for summary judgment dismissing plaintiff's Labor Law § 200 and common-law negligence claims; denied the owners' motion for summary judgment on their cross-claims for contractual indemnification against EmpireHD and Victorio's; denied EmpireHD's motion for summary judgment on their third-party claim for contractual indemnification as against Victorio's; and denied Victorio's motion for summary judgment dismissing the remaining cross-claims and third-party claims for common-law indemnification and contribution as against it.
The Appellate Division affirmed the Supreme Court, finding that since Plaintiff did not oppose the specific part of the relevant motions to dismiss the Labor Law §§240(1) claims, the court deemed the claim abandoned and upheld dismissal.
PRACTICE POINT: It always helps to oppose each point of each motion in order to avoid abandoning the claim.
 Labor Law § 241(6) (EDA)
The Appellate Division affirmed the Supreme Court, finding that the evidence raised triable issues as to whether plaintiff was caused to slip/trip on a defective step of a staircase that was the "only route" he could take to perform his assigned task pursuant to 12 NYCRR 23-1.7(e)(1). Issues of fact also remained as to whether the staircase was a "defined walkway or pathway used to traverse between discrete areas [(the open street and the inside of the building)] as opposed to an open area" as contemplated by 22 NYCRR 23-1.7(e)(1). Quigley v Port Auth. of N.Y. & N.J. (168 AD3d 65 [1st Dept 2018]), relied upon by defendants, was distinguishable. In Quigley, plaintiff's injuries were caused by an icy condition, causing him to slip and fall on snow-covered pipes located in an open area outside of defendant's construction shanty, which is more appropriately analyzed pursuant to Industrial Code § 23-1.7(d) that addresses "slipping hazards".
Labor Law § 200 and Common-Law Negligence (EDA)
The Appellate Division affirmed the Supreme Court finding that defendants failed to establish that the defect on the stairs was trivial as a matter of law. At his deposition, plaintiff identified photographic exhibits of the defect in the stairs and testified that the foot-wide defect was about one-inch deep. He further testified that he felt as if the defect he stepped into was at a different level than the rest of the steps, causing him to lose his balance as he carried 50 pounds of demolition debris down the stairs. In contrast, the project manager for general contractor EmpireHD described the area of the cracked step as a depression with an 1/8th inch differential. The conflicting testimony on this issue forecloses resolution on summary judgment (see e.g. Solomon v Diego Beekman Mut. Hous. Dev. Fund Corp., 190 AD3d 660, 660 [1st Dept 2021]).
Indemnity Issues in Labor Law (EDA)
The Appellate Division affirmed the Supreme Court finding that the owners and EmpireHD did not establish entitlement to conditional contractual indemnification under the two indemnification provisions. Factual issues exist as to whether their acts or omissions constituted the sole proximate cause of the accident, which, under both provisions, would preclude a right to indemnification (see Cackett v Gladden Props., LLC, 183 AD3d 419, 422 [1st Dept 2020]).
Finally, the Court affirmed that dismissal of the third-party claims and cross-claims against Victorio's for common-law indemnification and contribution was warranted because plaintiff was awarded worker's compensation benefits, and there was no evidence proffered to show that he suffered a grave injury (see Lopez v 18-20 Park 84 Corp., 235 AD3d 591, 592 [1st Dept 2025]; Clarke v Empire Gen. Contr. & Painting Corp., 189 AD3d 611, 612 [1st Dept 2020]).
Plaintiff was an electrician employed by B&G to perform telecommunications work as part of a larger project to construct new buildings for defendants. Plaintiff was injured when he fell while stepping backwards out of an elevator doorway. The elevator doorway was approximately 6 to 12 inches above the unfinished floor. Plaintiff testified that prior to the incident, he entered the crowded elevator on his way to his jobsite with his back facing the elevator doors. According to plaintiff, wooden ramps were usually placed next to elevator doors throughout the building to facilitate the moving of personnel, materials, tools via carts, and wheeled gang boxes. However, on the date of the incident, the fourth floor's ramp had been removed, creating a gap between the elevator doorway and the unfinished floor. As plaintiff exited the elevator, he stepped with one foot into this gap, and his weight transferred to his knee. Plaintiff's knee buckled, causing an injury.
The Supreme Court denied the motion by defendants City University Construction Fund, Memorial Sloan Kettering Cancer Center, Memorial Hospital for Cancer and Allied Diseases, and Turner Construction Company for summary judgment dismissing plaintiff's claims pursuant to Labor Law § 240(1), Labor Law § 200 and common-law negligence, and on its cause of action against third-party defendant B&G Industries LTD for contractual indemnification, awarded summary judgment to plaintiff on his claim pursuant to Labor Law § 240(1), and denied B&G's motion for summary judgment dismissing the third-party complaint.
Labor Law § 240(1) (EDA)
The Appellate Division unanimously reversed the Supreme Court finding that not every fall results in the "extraordinary protections of Labor Law § 240(1)" (Narducci v Manhasset Bay Assoc., 96 NY2d 259, 267 [2001]). The statute protects workers only from those falls stemming from the "extraordinary elevation risks" created by "the relative elevation at which the [work] must be performed" and not from "the usual and ordinary dangers of a construction site" (Toefer v Long Is. R.R., 4 NY3d 399, 407 [2005]).
PRACTICE POINT: There is no bright-line minimum height differential that determines whether an elevation hazard exists, and there must be a physically significant height elevation differential to trigger the protection of Labor Law § 240(1).
Labor Law § 200 and Common-Law Negligence (EDA)
The Appellate Division affirmed the Supreme Court finding that the accident arose from the means and methods of the work, as opposed to any inherent defect in the property, making the relevant inquiry whether defendants "exercised control or supervision over the work and had actual or constructive notice of the purportedly unsafe condition" (Alonzo v Safe Harbors of the Hudson Hous. Dev. Fund Co., Inc., 104 AD3d 446, 449 [1st Dept 2013]. Defendants failed to eliminate issues of fact as to whether defendant Turner was one of the parties tasked with placing elevator ramps on unfinished floors to close the gap between the doors and the floor, removing the ramps to allow flooring installation, or coordinating elevator access. The remaining defendants also failed to establish their freedom from negligence as their precise roles, if any, in the construction projects were unclear.
Indemnity Issues in Labor Law (EDA)
The Appellate Division reversed the Supreme Court finding that the contractual indemnification claims against B&G should have been dismissed because plaintiff's only remaining causes of action for common-law negligence and Labor Law § 200 necessarily contemplate negligence on defendants' part (see General Obligations Law § 5-322.1 [1]. Further, defendants' common-law indemnification and contribution claims were deemed abandoned as they did not address those claims in either their opposition to B&G's motion for summary judgment dismissing the claims or in their respondents' brief on this appeal.
Finally, the Appellate Division found that the motion to dismiss third-party B&G's counterclaims against defendants should be granted, because B&G did not oppose dismissal of those claims in Supreme Court and expressly failed to do so on defendants' appeal.
Plaintiff fell from a scaffold that tipped over while his coworker was pushing it. The Supreme Court granted plaintiffs' motion for partial summary judgment on his Labor Law § 240(1) claim.
Labor Law § 240(1) (EDA)
The Appellate Division unanimously affirmed finding that Plaintiff established that defendants failed to provide plaintiff with a scaffold that was "constructed, placed and operated as to give proper protection" (Labor Law §240[1] [emphasis added]). Both plaintiffs' and defendants' experts attributed the accident to the operation of the scaffold. The Appellate Division found that plaintiff's participation in the process of moving the scaffold by riding it while it was in motion was not the sole proximate cause of the accident. Nothing in the record suggests that the process was the product of plaintiff's independent devise. Defendants also failed to raise a triable issue of fact as to whether plaintiff was a recalcitrant worker. Defendant general contractor's instruction not to ride or surf the scaffold cannot serve as the basis for a recalcitrant worker defense
PRACTICE POINT: To prove the Sole Proximate Cause defense, a defendant must show that there were adequate safety devices, plaintiff knew they were available, plaintiff was expected to use them, and he chose for no good reason not to do so. If the plaintiff did not act alone, i.e. colluded, connived, or conspired with a co-worker, he cannot be the SOLE reason for his injury, hence the reference to “plaintiff’s independent devise” in the decision.
Plaintiff was injured while performing work on property owned by defendant Cheer Hall in Rockland County. He testified that in November 2020 he fell from a ladder while preparing to put on a roof on a private home. He was employed by LaBozz and took his direction only from his supervisor. The ladder he used belonged to LaBozz. Defendant Cheer Hall has no operating budget, does not file corporate tax returns and has never filed tax returns. For tax purposes, Cheer Hall is considered a “disregarded entity”, which means that any tax liability of Cheer Hall would be on its sole member. The Supreme Court granted the defendant's motion for summary judgment dismissing the Labor Law §§ 240(1) and 241(6) claims, and denied the plaintiffs' cross-motion for summary judgment on those causes of action.
 Labor Law § 240(1) (JLD)
The Appellate Court held that the defendant’s submissions were sufficient to establish that defendant’s use of the property was entirely for residential purposes and the construction work being performed by the defendant was directly related to the residential use of the property. Defendant established that it did not direct or control the method and manner of the injured plaintiff’s work. The Court reaffirmed its previous holdings that the homeowner exemption does not apply to property owners who use their one or two-family premises entirely and solely for commercial purposes, however, the exemption is applicable when the work directly relates to the residential use of the home, even if the work also serves a commercial purpose.
PRACTICE POINT: When attempting to set forth the homeowner exemption, it is important to emphasize the residential usage of the property and establish that any commercial purpose is not the intent of the work being performed.
Plaintiff, who was employed as a "diesel technician" for the third-party defendant Maverick, which was owned by Anthony Trupia, was building a carport structure when he was caused to fall and was injured. The property was owned by 57th Road. Anthony Trupia was the sole shareholder of 57th Road. Phantom, a trucking company, brought trucks onto the property as needed for maintenance and repair by Maverick. Plaintiff testified that Mr. Trupia instructed him to climb to the top of the frame to stretch the canvas across and that Mr. Trupia himself handed plaintiff the canvas. Mr. Trupia denied that this occurred. Mr. Trupia testified that Phantom requested the construction of the car port and that Phantom had a written lease to use the yard. Carlos Bautista, owner of Phantom, denied that Phantom requested construction of the car port and further denied that Phantom was a lessee of the premises. There is neither a contract nor a lease in the record. The Supreme Court denied plaintiff's motion for summary judgment on the Labor Law § 240(1) claim against the defendant Phantom Carting, Inc.
Labor Law § 240(1) (JLD)
The Appellate Court concluded that the plaintiff failed to eliminate all triable issues of fact as to whether Phantom, a lessee of the subject premises, controlled and supervised his work. The trial court properly denied plaintiff’s motion as to Labor Law 240(1).
PRACTICE POINT: A lessee of real property who hires a contractor and has a right to control work is considered to be an owner within the meaning of the law. To defeat a plaintiff’s motion for summary judgment, establish that the defendant did not have control and supervision over the plaintiff’s work.
The plaintiff was struck by a delivery gate at a construction site at which he was working. The Supreme Court (1) granted the motion of the defendants 1719 27 ST, LLC, and 27 ST CON, LLC, for summary judgment dismissing the common-law negligence claim and a the Labor Law § 200 claim against them, (2) granted the motion of the defendants J. Petrocelli & Sons Construction, Inc., and J. Petrocelli Construction, Inc., for leave to extend the time to move for summary judgment, and for summary judgment dismissing the common-law negligence claim and Labor Law § 200 claim against them, and (3) denied the plaintiff's cross-motions for summary judgment on the common-law negligence claims and Labor Law § 200 claims against the defendants 1719 27 ST, LLC, and 27 ST CON, LLC, and the defendants J. Petrocelli & Sons Construction, Inc., and J. Petrocelli Construction, Inc., respectively.
Labor Law § 200 and Common-Law Negligence (JLD)
The Appellate Court concluded that the ST Defendants established, prima facia, that they did not have the requisite control over the work site and did not create the allegedly dangerous condition nor had actual or constructive notice of its condition. The Court also concluded that the trial court properly granted the branch of the Petrocelli defendants’ motion which was for leave for time to extend to move for summary judgment because at the time the note of issue was filed, there remained significant discovery. However, the trial court should have denied those branches of the Petrocelli defendants’ motions dismissing the causes of action for common law negligence and Labor Law § 200 because the Petrocelli defendants failed to establish that they did not exercise a significant degree of control and supervision of the construction site, such that it was not delegated the authority and duties of a general contractory. The Appellate Court concluded that while a construction manager is generally not considered a contractor responsible for the safety of workers at a construction site, it may become responsible if it has been delegated the authority and duties of a general contractor, or if it functions as an agent of the owner of the premises.
The plaintiff was injured when he fell from a six-foot tall A-frame ladder while performing electrical work as an employee of the third-party defendant Matia Electrical Corp. The plaintiff was working at a construction site managed by the defendant third-party plaintiff Top 8 Construction Corp., the general contractor, on premises owned by the defendants. The plaintiff moved for summary judgment on the issue of liability on the cause of action alleging a violation of Labor Law § 240(1) insofar as asserted against the defendants. The Supreme Court denied the motion.
Labor Law § 240(1) (JLD)
The Appellate Court concluded that the defendant raised triable issue of fact as to whether the plaintiff’s conduct was the sole proximate cause of his injuries. The court concluded when credible evidence reveals differing versions of the accident, such that defendants would not be liable under one of those versions, questions of fact exist that make summary judgment inappropriate. The Appellate Division opined that a plaintiff’s intentional or negligent conduct may be the sole proximate cause of the worker’s injuries when adequate safety devices are provided, but the worker does not use them, or misuses them.
PRACTICE POINT: At deposition, be sure to lay a foundation that will permit you to raise a version of the accident that would establish plaintiff’s own conduct was a sole proximate cause of his or her injuries.
Plaintiff was an HVAC maintenance worker employed by the American Museum of Natural History who commenced this action to recover damages for personal injuries against the defendant, an independent contractor hired by the Museum, alleging, inter alia, common-law negligence. The plaintiff alleged that in October 2020, he was climbing a ladder owned by the defendant when one of the rungs cracked, causing him to fall and sustain injuries. The defendant moved for summary judgment dismissing the cause of action alleging common-law negligence. The trial court granted defendant’s motion.
Labor Law § 200 and Common-Law Negligence (JLD)
The Appellate Division reversed the trial court’s decision, finding that the evidence defendant submitted in support of its motion failed to eliminate triable issues of fact as to whether it created an unreasonable risk of harm by leaving a defective ladder on the premises and whether that risk was a proximate cause of the plaintiff’s injuries.
August 19, 2026
Appellate Division, Second Department
The plaintiff, an ironworker, allegedly was injured while working at a construction site while in the process of moving a steel I-beam using "spreader hooks" attached to a crane. The plaintiff commenced this action to recover damages for personal injuries, asserting causes of action alleging common-law negligence and violations of Labor Law §§ 200, 240(1), and 241(6). Plaintiff testified that on the date of the accident, he and a coworker were unloading a delivery of steel beams and were "shaking out" the steel, a process which involved using spreader hooks attached to the crane to lift the beams up and off the truck and placing them on the ground. The plaintiff and his coworker were using the spreader hooks "like a pendulum" to grab a steel beam from one pile to swing it over to another pile. According to the plaintiff, at the time of his accident, the piece of steel that the plaintiff and his coworker were moving was five feet off the ground. As the plaintiff and his coworker guided the beam, his coworker "let go" of the beam, at which time the beam began swinging, dragging the plaintiff. A crane operator confirmed that the beam swung out five to six feet away from the crane after he lifted the beam. After the steel moved, the plaintiff put his arm around it. According to the plaintiff, when the steel moved away from him, it was no longer at the height of five feet above the ground, it was more "like 3 feet." The beam hit a pile of steel beams on the ground, which caused the plaintiff to be "jerked . . . forward" and suffer injuries. The plaintiff moved for summary judgment on Labor Law 240(1) and 241(6) as against defendant OLP Hauppauge, LLC, (“OLP”) which owned the construction site, and LMJ Management & Construction, (“LMJ”) the general contractor, and for common law negligence as against Dave Sandel Cranes, Inc. The trial court denied plaintiff’s motions.
Labor Law § 240(1) (JLD)
In cases involving falling objects, the plaintiff must demonstrate that at the time the object fell, it was either being hoisted or secured, or required being hoisted or secured. Here, the plaintiff established, prima facie, via deposition transcripts of the plaintiff and the crane operator, that the beam being hoisted at the time of the incident was an object that required securing for the purposes of the undertaking, and the harm flowed directly from the application of forces of gravity to the beam. In response, defendants OLP and LMJ failed to raise a triable fact. The Appellate Division reversed the trial court’s finding and determined that the trial court should have granted plaintiff’s motion for summary judgment on the issue of liability as to Labor Law 240(1).
PRACTICE POINT: In a falling object case, the object does not need to strike the plaintiff; it is often simply enough that gravity from the object falling causes harm to the plaintiff to establish liability.
Labor Law § 241(6) (JLD)
Given the court’s conclusions on Labor Law 240(1), it does not address the Labor Law 241(6) claims.
Labor Law § 200 and Common-Law Negligence (JLD)
Given the court’s conclusions on Labor Law 240(1), it did not find merit in the remaining claims.
The plaintiff was injured while performing construction work on premises owned by the defendant LS-14 Ave, LLC. The defendant Ryder Construction, Inc. was acting as the general contractor on the project and hired the plaintiff's employer, the third-party defendant, Glenco Contracting Group, Inc., as a subcontractor on the project. At the time of the accident, the plaintiff was placing rubber caps on the end of exposed rebar when he bypassed a safety railing and stepped onto a piece of plywood, which collapsed, causing him to fall approximately 10 to 11 feet into an opening below. Glenco moved for summary judgment on the Labor Law 241(6), which the trial court granted. Plaintiff also moved for summary judgment on the issue of liability on the 240(1) cause of action; the trial court denied plaintiff’s motion.
Labor Law § 240(1) (JLD)
The Appellate Division affirmed the trial court’s findings, concluding that plaintiff failed to eliminate triable issues of fact as to whether plaintiff’s conduct was the proximate cause of the accident. The deposition testimony raised questions of fact as to whether the safety railing provided proper protection from the elevation-related risks, and whether plaintiff’s decision to bypass the safety railing was the sole proximate cause of the accident.
PRACTICE POINT: To prove the Sole Proximate Cause defense, a defendant must show that there were adequate safety devices, plaintiff knew they were available, plaintiff was expected to use them, and he chose for no good reason not to do so.
Labor Law § 241(6) (JLD)
Plaintiff argued only that LS-14 and Ryder violated Industrial Code 23-1.15, and did not raise an issue of a violation of that Industrial Code provision before the Supreme Court as to Glenco, and thus, this contention is improperly raised for the first time on appeal.
New York Industrial Code Regulations (EDA)
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Regulation § 23–1.28 Hand-propelled vehicles
(e) Storage. When not in use, hand-propelled vehicles shall be stored in locations away from passageways and work areas.
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Regulation § 23–1.28(e) is likely sufficiently specific to support a Labor Law § 241(6) cause of action as it provides specific and particular actions to take and/or avoid.
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No Appellate Court has ruled on the specificity or application of Regulation § 23–1.28(e) to date.
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Labor Law Pointers
Editor
David R. Adams
Associate Editor
Eric D. Andrew
Associate Editor
Patrice C. S. Melville
Associate Editor
Ashley M. Cuneo
Associate Editor
Robert H. Flynn
Associate Editor
Jessica L. Deren
Associate Editor
Marten R. Violante
Labor Law Team
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David R. Adams, Team Leader
[email protected]
Patrice C. S. Melville
[email protected]
Brian F. Mark
[email protected]
Elizabeth K. Ognenovski
[email protected]
Robert H. Flynn
[email protected]
Joseph P. Mendoza
[email protected]
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