Phillips v. City of New York
The plaintiff, an employee of Dag Dee Tool Rentals, Inc., was injured while repairing a 'loader' at a landfill owned by the City of New York, which was managed by Cross Bay Contracting Corp. The injury occurred when the loader's 'drop arm' fell on his hand from shoulder height. The Supreme Court initially granted summary judgment, dismissing claims based on Labor Law § 240 (1) and § 241 (6). The appellate court affirmed this decision. It ruled that Labor Law § 240 (1) did not apply to routine maintenance or objects falling from minimal heights, and § 241 (6) was inapplicable as the plaintiff was not engaged in 'construction work' and failed to cite a specific, concrete industrial code violation.