Rosenberg v. Ben Krupinski General Contractors, Inc.
Robert Rosenberg, an employee of an alarm company, was allegedly injured after tripping over cardboard at a construction site. He and his wife sued Ben Krupinski General Contractors, Inc. (the general contractor) and Dave Mims Fifth Generation Painting Contractors (a subcontractor) under Labor Law §§ 200 and 241 (6). The Supreme Court granted summary judgment to Mims but denied Krupinski's motion for similar relief. On appeal, the order was modified; Krupinski's motion for summary judgment dismissing the Labor Law § 200 claim was granted, as Krupinski established it had no authority to control the activity causing the injury. However, the motion for summary judgment on the Labor Law § 241 (6) claim was properly denied due to triable issues of fact regarding whether the accident occurred in a passageway or work area and whether specific regulations (12 NYCRR 23-1.7 (e) (1) or (2)) were violated, and whether Krupinski was still the general contractor at the time of the accident.