Velasquez v. 795 Columbus LLC
The plaintiff sustained injuries after slipping on mud, rocks, and water at a construction site due to rain and a water main break. The Supreme Court granted the plaintiff's motion for partial summary judgment on Labor Law § 241 (6) and Labor Law § 200 claims against defendant Tishman Construction and denied the defendants’ cross-motion for summary judgment. The Appellate Division unanimously affirmed this decision, holding that 12 NYCRR 23-1.7 (d) (slipping hazards) was an applicable predicate for the Labor Law § 241 (6) claim, as the muddy condition constituted a 'foreign substance' on the 'floor'. The court found that Tishman Construction had notice of the hazardous condition and failed to rebut the plaintiff's prima facie showing of negligence. The claim for lost wages was appropriately deferred to trial as an issue of damages.