Walsh v. Kenny
The plaintiff, Patrick Walsh, appealed an order from the Supreme Court, Suffolk County, which granted summary judgment to the defendant, Edward Kenny, dismissing Walsh's causes of action for common-law negligence and violations of Labor Law §§ 200 and 241 (6). Walsh was injured while performing carpentry work on Kenny's backyard deck. The Appellate Division, Second Department, reversed the lower court's order. The Court found that Kenny failed to establish, prima facie, that he did not direct or control Walsh's work, which is required for the homeowner's exemption under Labor Law § 241 (6) to apply. Similarly, Kenny failed to eliminate triable issues of fact regarding his authority to supervise or control the work, precluding summary judgment on the Labor Law § 200 and common-law negligence claims.