Quigley v. Port Auth. of N.Y. & N.J.
Plaintiff Thomas Quigley sustained injuries after slipping on snow-covered pipes located directly outside his employer's work site shanty. The case involved claims under Labor Law § 241 (6) based on alleged violations of Industrial Code sections 12 NYCRR 23-1.7 (d), (e)(1), and (e)(2), as well as common-law negligence and Labor Law § 200. The court modified a prior order, denying defendants' motion to dismiss the Labor Law § 241 (6) claim predicated on 12 NYCRR 23-1.7 (d), finding an issue of fact regarding whether the accident occurred in a walkway. It affirmed the dismissal of the claim based on 12 NYCRR 23-1.7 (e)(1) as inapplicable to outdoor areas, but affirmed the denial of dismissal for claims based on 12 NYCRR 23-1.7 (e)(2), 12 NYCRR 23-2.1 (a)(1), common-law negligence, and Labor Law § 200. The appellate court concluded that defendants failed to demonstrate lack of notice regarding the dangerous condition.