Kollmer v. Slater Electric, Inc.
The plaintiff appealed a judgment from the Supreme Court, Nassau County, which dismissed her causes of action alleging a violation of Labor Law § 241 (6) in an action for wrongful death. The decedent, an employee of Delta Wells Inc., was fatally injured by a backhoe on land owned by the defendant, Slater Electric, Inc. The trial court had dismissed the Labor Law claim and ruled an OSHA violation inadmissible. The Appellate Division reversed the judgment, holding that Labor Law § 241 (6) imposes a nondelegable duty on owners, irrespective of their control over the worksite, and that the plaintiff's offer of proof established a prima facie case. The court reinstated the plaintiff's causes of action and granted a new trial, but affirmed that the specific OSHA settlement was inadmissible as an admission.