Sanders v. Sanders-Morrow
Steven Sanders, the plaintiff, appealed an order granting summary judgment to the defendants Carolyn Sanders-Morrow, William Morrow, and Dolores Morrow in a personal injury action. Sanders sustained injuries from a ladder fall while removing gutters from a property owned by Carolyn and Dolores, and occupied by William. The Appellate Division, Second Department, affirmed the lower court's decision, which dismissed the plaintiff's claims under Labor Law §§ 200, 240(1), 241(6), and common-law negligence. The court found that Carolyn and Dolores were entitled to the homeowner's exemption under Labor Law §§ 240(1) and 241(6) as the property was a one-family dwelling and they did not direct or control the work. William, though not an owner, was also not liable as a contractor or agent due to lack of supervisory control. Furthermore, all defendants were exempt from liability under Labor Law § 200 and common-law negligence as the injuries stemmed from the manner of work, not a dangerous premises condition, and they lacked supervisory authority over the plaintiff's work.