Cappiello v. Telehouse International Corp. of America
Plaintiff Carlo Cappiello, a carpenter, sustained permanent vision loss in his left eye when a masonry nail ricocheted while he was building a plywood form at a construction site. He sued the site owner, Telehouse, and general contractor, Kajima, for negligence and Labor Law violations, specifically concerning the failure to provide safety goggles. The Supreme Court initially granted summary judgment to the defendants, dismissing the complaint. The appellate court reversed this decision in part, reinstating claims under Labor Law § 241 (6) and specifically citing regulations 12 NYCRR 23-1.8 (a) and 12 NYCRR 19.4 (a) regarding eye protection. The court rejected a narrow interpretation of safety requirements, found a triable issue of fact regarding the foreseeability of the eye hazard, and also reinstated the derivative claim for loss of consortium.