Carollo v. Tishman Construction & Research Co.
The court reviewed postverdict motions in an action under Labor Law sections 240 and 241, where a jury found Tishman Construction and Research Co., Inc. (Tishman), Anthony Muratore Contracting Co., Inc. (Muratore), and Die Under-hill (Die) liable for a laborer's injuries, with Tishman being passively negligent. Tishman's motion to dismiss the verdict was denied, as the court determined Tishman functioned as a 'contractor' or 'owner's agent' under the Labor Law despite its 'construction manager' title. Furthermore, the court granted Tishman's motion for 100% contractual indemnification from Muratore and Die. This decision affirmed the validity of their indemnification clauses, ruling they were not void under General Obligations Law section 5-322.1(1) given Tishman's passive negligence and the parties' insurance provisions. The case underscores the broad interpretation of 'contractor' duties under Labor Law and the enforceability of indemnification agreements between actively and passively negligent parties.