Rendon v. Callaghan
The plaintiff, Vicente Rendon, sustained injuries after a garage roof he was repairing on premises owned by the defendant, Anna Callaghan, collapsed. Rendon filed a personal injury lawsuit, alleging common-law negligence and violations of Labor Law §§ 200, 240 (1), and 241 (6). The Supreme Court granted summary judgment to Callaghan, ruling that she did not supervise the work and was protected by the homeowners' exemption under Labor Law §§ 240 (1) and 241 (6). The Appellate Division, Second Department, affirmed this decision, concluding that Callaghan had no notice of any structural defect for the Labor Law § 200 claim. The court further held that the homeowners' exemption applied because the garage served a residential purpose as an 'extension of the dwelling,' despite being on a separate lot, and Callaghan did not direct or control the plaintiff's work.