Fitzgerald v. New York City School Construction Authority
The plaintiffs appealed an order from the Supreme Court, Queens County, which granted summary judgment to the defendants New York City School Construction Authority, New York City Board of Education, and Pillar Construction, Inc., dismissing causes of action alleging a violation of Labor Law § 241 (6). The case involved an injured plaintiff who was struck by a backing forklift without a signal person. The plaintiffs argued a violation of 12 NYCRR 23-9.7 (d), which requires guidance for backing trucks. The appellate court affirmed the summary judgment, finding that the specific safety regulation cited (12 NYCRR 23-9.7 (d)) was inapplicable to forklifts, which are governed by 12 NYCRR 23-9.8, a provision lacking the explicit guidance requirement. As the plaintiffs failed to raise a triable issue of fact, the Supreme Court's decision was upheld.