Narrow v. Crane-Hogan Structural Systems, Inc.
Plaintiff, an employee of Elderlee, Inc., sustained a herniated disc while lifting a box beam after a co-worker dropped their end. Plaintiff and his wife sued the unnamed general contractor (defendant) under Labor Law §§ 200, 240 (1), and 241 (6). The Supreme Court granted defendant's motion for summary judgment, dismissing the complaint. On appeal, the court affirmed the lower court's decision, finding that the injury was not an elevation-related hazard under Labor Law § 240 (1) and that the alleged regulatory violations under Labor Law § 241 (6) were general safety standards, not concrete specifications. The plaintiffs did not pursue their appeal concerning Labor Law § 200.