Case No. 2022 NY Slip Op 04811 [208 AD3d 492]Regular Panel DecisionAug 03, 2022 Murphy v. 80 Pine, LLC
Daniel Murphy, an employee of Empire Office, Inc., sustained a knee injury after tripping over an electrical conduit ('stub up') at a worksite owned by 80 Pine, LLC, and managed by Rudin Management Co., Inc. He and his spouse filed a consolidated action alleging common-law negligence and violations of Labor Law §§ 200 and 241(6) against the owners, general contractor Structure Tone, Inc., and various electrical contractors including United States Information Systems, Inc. (Systems), USIS Electric, Inc. (Electric), and Bigman Brothers, Inc. (Bigman). The defendants moved for summary judgment. The Supreme Court, Kings County, largely denied these motions. On appeal, the Appellate Division modified the Supreme Court's order, granting summary judgment to Systems on Labor Law § 200, common-law negligence, and certain Labor Law § 241(6) claims, and dismissing Bigman's cross-claims against Systems. It also granted summary judgment to Electric for the Labor Law § 241(6) claim predicated on 12 NYCRR 23-1.30, and to the owners and Structure Tone for Labor Law § 200 and common-law negligence claims. However, it affirmed the denial of summary judgment for Electric regarding Labor Law § 200 and common-law negligence, and for the owners and Structure Tone regarding specific Labor Law § 241(6) claims. The court also affirmed the denial of Electric's motion to dismiss Systems' cross-claim for contractual indemnification and the denial of the owners' and Structure Tone's motion for contractual indemnification against Bigman.
Construction AccidentLabor LawSummary JudgmentPremises LiabilityCommon-Law NegligenceHazardous ConditionElectrical ConduitWorkplace SafetyAppellate ReviewIndemnification