Iveson v. Sweet Associates, Inc.
Plaintiff Leonard F. Iveson sustained personal injuries while working on a renovation project in the State Education Building, attempting to cross from a new catwalk furnished by STS Steel, Inc. to an older one. He, along with other plaintiffs, commenced an action alleging violations of Labor Law §§ 200, 240 (1), and 241 (6) against prime general construction contractor Sweet Associates, Inc. and subcontractor STS Steel, Inc. The Supreme Court granted STS Steel, Inc.'s cross-motion for summary judgment to the extent of dismissing the Labor Law § 240 (1) claim, finding STS was not an owner or general contractor and lacked the authority to supervise or control Iveson's work. The Appellate Court affirmed this dismissal, emphasizing that liability under Labor Law § 240 (1) for a subcontractor requires a showing of control over the work and the authority to enforce safety practices, which was not demonstrated here.