Friot v. Wal-Mart Stores, Inc.
Plaintiff, an employee of a subcontractor, was injured on a construction site for Wal-Mart when a large mass of earthen fill dislodged, pinning him against a vehicle. He commenced an action against defendant Pike Company, Inc. (general contractor) and defendant Wal-Mart Stores, Inc. (owner), alleging violations of Labor Law §§ 200, 240 (1), and 241 (6). The Supreme Court initially dismissed the complaint but, upon reargument, reinstated the Labor Law § 200 claim while adhering to the dismissal of the others. The appellate court affirmed the dismissal of the Labor Law § 240 (1) and § 241 (6) claims, finding the latter inapplicable to ground-level accidents and the former not covering the type of elevation-related risk. However, it was determined that further discovery was needed regarding Pike's authority and control over the work site's safety to resolve the Labor Law § 200 claim.