Levy v. Baumgarten
Yehonatan Levy and his wife appealed a Supreme Court order that granted summary judgment to Levi Baumgarten, dismissing their personal injury complaint. The injury occurred when Levy, a worker on Baumgarten's home renovation, had a saw blade embed in his hand. Plaintiffs alleged violations of Labor Law §§ 200 and 241(6), but the Supreme Court applied the homeowner's exemption and found no supervision or control by Baumgarten. The Appellate Division affirmed, concluding that incidental commercial use of the home did not forfeit the homeowner's exemption and Baumgarten's actions did not constitute direction or control over the work. Consequently, the summary judgment dismissing the Labor Law claims was upheld.