Allison Gammons v. City of New York
This is a dissenting opinion arguing that Labor Law § 27-a (3) (a) (1), the "general duty" clause, is too broad to serve as a predicate for a General Municipal Law § 205-e cause of action without citing a specific regulation. The dissent contrasts this general provision with more specific legal duties found in previously cited cases like Gonzalez v Iocovello and Cosgriff v City of New York, which involved Vehicle and Traffic Law or local administrative codes. It emphasizes that plaintiffs should be required to identify specific rules or regulations that were violated, similar to the requirements for Labor Law § 241 (6) claims. The dissenting judge suggests remanding the case to consider the applicability of a specific Occupational Safety and Health Act provision, 29 CFR 1910.23 (c) (1), which the plaintiff also asserted. The order, insofar as appealed from, was affirmed by the majority.