Cannon v. Putnam
This case examines the scope of the dwelling-owner exemption under Labor Law § 240 (1) and § 241, which exempts owners of one and two-family dwellings who do not direct or control the work from certain safety duties. Defendant Albert Putnam owned a property with both residential and commercial uses. Plaintiff Robert Cannon was injured while installing a floodlight for aesthetic purposes related to Putnam's residence. The Court of Appeals affirmed the lower courts' decision, holding that the exemption applies when the commercial activities are housed in separate structures, and the work is unrelated to those commercial structures, focusing on the 'site and purpose of the work.' The court also found that Putnam did not direct or control the work.