Moses v. Pinazo
Isidore Moses, a laboratory clerk at New York Community Hospital, sustained personal injuries after slipping on glue during a re-tiling project in the Intensive Care Unit, where Fernando Pinazo, through a subcontractor, was performing work. Moses, despite observing the glue, attempted to navigate around it and subsequently fell. The Supreme Court granted summary judgment dismissing his complaint, a decision which was upheld on appeal. The appellate court determined that Moses did not fall within the protected class of workers under Labor Law § 241 (6) for construction-related hazards, as his role was not connected to the construction work. Furthermore, the court found that the glue constituted an integral part of the re-tiling process, not a covered obstruction under Industrial Code 12 NYCRR 23-1.7 (e). The defendant Pinazo was also found to have no common-law duty to warn, as the hazard was readily observable by Moses, who acknowledged seeing the glue prior to his accident.