Davis v. Wyeth Pharmaceuticals, Inc.
A construction laborer (plaintiff) sustained injuries while moving a heavy filtration unit, leading him to file a negligence claim and allege violations of Labor Law §§ 200 and 241 (6) against Wyeth Pharmaceuticals, Inc., and three Stantec-related entities. After consolidating the actions, the plaintiff sought to add a claim under Labor Law § 240 (1), which the Supreme Court denied. On appeal, the court affirmed this denial, ruling that the proposed amendment lacked merit. The appellate court clarified that the Runner precedent did not broaden the scope of Labor Law § 240 (1) to include injuries not arising from a significant elevation differential. The decision concluded that the plaintiff's injury, resulting from an object tipping during horizontal movement, did not fall under the statute's protections for elevation-related risks.