Kittelstad v. Losco Group, Inc.
This case involves a plaintiff's claims under Labor Law §§ 240 (1), 241 (6), and 200, and common-law negligence. The court addressed whether Jacobs and Clean Air were statutory agents of the property owner (the State). Jacobs's contractual obligations and superintendent's authority indicated comprehensive oversight, raising a question of fact regarding its agency status. Clean Air also retained significant supervisory authority over its subcontractor, Campbell, despite its claims to the contrary, thus establishing a question of fact regarding its control. Additionally, the court found Industrial Code (12 NYCRR) § 23-1.7 (b) applicable and held that the Labor Law § 200 and common-law negligence claims against Clean Air should not have been dismissed due to questions of fact concerning dangerous conditions or notice. Consequently, Clean Air was not entitled to summary judgment on its contractual indemnification claim against Campbell.