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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Brooks v. Judlau Contracting, Inc.

This appeal addresses whether General Obligations Law § 5-322.1 permits a partially negligent general contractor to enforce an indemnification provision against its subcontractor for damages attributable to the subcontractor's negligence. The plaintiff, Stephen J. Brooks, an ironworker employed by subcontractor Thunderbird Constructors, Inc., sustained injuries and sued the general contractor, Judlau Contracting, Inc. Judlau asserted a third-party claim for contractual indemnification against Thunderbird, which was initially dismissed by lower courts on the grounds that Judlau's partial negligence precluded indemnification under the statute. The Court of Appeals reversed, holding that the statute does permit such indemnification as long as the provision does not seek to indemnify the general contractor for its own negligence, but only for that portion attributable to the subcontractor. The court clarified that the phrase 'to the fullest extent permitted by law' limits the subcontractor's obligation to its own negligence, thereby enforcing the indemnification provision and remitting the case for further proceedings.

IndemnificationSubcontractor LiabilityGeneral Contractor NegligenceConstruction AccidentGeneral Obligations LawWorkers' Compensation LawContractual IndemnificationPartial NegligenceHold Harmless ClauseThird-Party Claim
References
11
Case No. MISSING
Regular Panel Decision
Jan 05, 1999

Light v. Antedeminico

Roger Light, a maintenance worker for Pawling Corp., initiated this action against Anthony Antedeminico d/b/a Tony’s Construction, a subcontractor, seeking damages for personal injuries sustained after falling into an excavated pit. The Supreme Court, Dutchess County, initially denied the defendant's motion for summary judgment to dismiss the common-law negligence claim, maintaining that triable issues of fact existed regarding the defendant's potential negligence. Upon reargument, the Supreme Court adhered to its original decision, prompting the defendant to appeal. The appellate court subsequently reversed the lower court's order, granting the defendant's motion for summary judgment and dismissing the common-law negligence cause of action. The court reasoned that the defendant successfully demonstrated a lack of sufficient control over the construction site, thereby owing no duty of care to the injured plaintiff, and the plaintiffs failed to present a triable issue of fact to counter this.

Personal InjuryCommon-Law NegligenceSummary JudgmentAppellate ReviewDuty of CareConstruction SiteSubcontractor LiabilityPremises LiabilityDutchess CountyNew York Law
References
4
Case No. MISSING
Regular Panel Decision

O'Neil v. Roman Catholic Diocese

A student worker at St. Ephrem’s Church (the plaintiff) experienced sexual harassment from a visiting priest. After a particularly egregious incident, she informed other parish priests who promptly referred her to law enforcement. The plaintiff subsequently sued the Roman Catholic Diocese of Brooklyn and St. Ephrem’s Church for sexual harassment, negligence, negligent hiring, and negligent supervision, arguing they should have known of the priest's propensity. The Supreme Court, Kings County, granted summary judgment to the Diocese defendants, dismissing the plaintiff's claims, finding they lacked actual or constructive knowledge. The appellate court affirmed this decision, concluding that the defendants met their burden in demonstrating no prior knowledge of the visiting priest's conduct and acted diligently once informed.

Sexual HarassmentHostile Work EnvironmentNegligenceNegligent HiringNegligent SupervisionSummary JudgmentEmployer LiabilityConstructive KnowledgeDiscriminationNew York City Human Rights Law
References
8
Case No. MISSING
Regular Panel Decision

Aluminum Co. of America v. Commercial Contracting Co. of San Antonio

Alcoa sued Commercial Contracting Co. based on an indemnity clause in their contract, seeking to recover a $6,000 settlement paid to Bobby G. Holloway and associated legal fees. Holloway, a subcontractor's employee, was injured at Alcoa's plant due to what Alcoa alleged was negligence by Commercial's subcontractor or by an Alcoa employee who was a 'borrowed servant' of the subcontractor. The jury found that the subcontractor's employees were not negligent and that Alcoa's employees were not borrowed servants. The appellate court affirmed the trial court's judgment, concluding that the evidence supported the jury's findings that Alcoa's employees were not borrowed servants and that negligence was not conclusively established against the subcontractor.

Indemnity ContractBorrowed EmployeeEmployer NegligenceSubcontractor NegligenceProximate CausationJury FindingsAppellate AffirmationContractual LiabilityPersonal Injury LitigationWorkmen's Compensation Settlement
References
10
Case No. MISSING
Regular Panel Decision

Kendle v. August Bohl Contracting Co.

Samuel Kendle, an employee of subcontractor Clifford Quay & Sons, Inc., was injured while operating a motorized wheelbarrow at a construction site in Saratoga County. He fell when plywood covering a trench, allegedly dug by defendant August Bohl Contracting Company, Inc. (Bohl), buckled. Kendle and his wife sued the property owners, construction manager, and Bohl, alleging violations of Labor Law § 200 and common-law negligence. The Supreme Court dismissed Labor Law §§ 240 and 241 claims but denied Bohl's cross-motion to dismiss the Labor Law § 200 and negligence causes of action. On appeal, the court reversed the Supreme Court's decision, finding that Bohl did not exercise supervisory control over Kendle's work, a necessary element for Labor Law § 200 liability. The court also dismissed the negligence claim, noting that the trench was readily observable to the experienced plaintiff.

Construction AccidentMotorized Wheelbarrow InjuryWorksite HazardSubcontractor NegligenceLabor Law LiabilityLack of Supervisory ControlCommon-Law NegligenceSummary Judgment AppealAppellate ReversalPlywood Failure
References
7
Case No. MISSING
Regular Panel Decision

Health Acquisition Corp. v. Program Risk Management Inc.

The plaintiffs, home health care companies (Health Acquisition Corp., Bestcare, Inc., and Aides at Home, Inc.), sued various defendants, including accounting firm DeChants, Fuglein & Johnson, LLP (DFJ) and actuarial firm SGRisk, LLC, for professional negligence and negligent misrepresentation. The suit arose after the self-insurance trust they were members of became insolvent, leading to significant assessments from the Workers' Compensation Board. Plaintiffs alleged defendants concealed the trust's true financial state and their liability risks. The Supreme Court initially dismissed claims against DFJ and SGRisk. However, the appellate court reversed this decision, finding the complaint adequately alleged "near-privity" and negligence against both firms, even clarifying that actuaries could be held liable for common-law negligence despite not being licensed professionals for malpractice claims. A partial appeal concerning leave to amend the complaint was dismissed.

professional negligencenegligent misrepresentationCPLR 3211 (a)motion to dismissgroup self-insurance trustWorkers' Compensation Law § 50joint and several liabilityactuariesaccountantsnear-privity
References
15
Case No. 01-22-00434-CV
Regular Panel Decision
Jun 01, 2023

Metropolitan Transit Authority of Harris County, Texas v. Augustine Cruz Melendez, A. Morfin Trucking LLC, and Trans-Global Solutions, Inc.

The Metropolitan Transit Authority of Harris County, Texas (Metro) appealed a summary judgment granted in favor of Trans-Global Solutions, Inc. (TGS). Metro had sued TGS for negligence, negligence per se, and gross negligence following an accident where a dump truck, driven by an employee of a TGS subcontractor, collided with a Metro train. Metro alleged that TGS failed to uphold its duties regarding safety, traffic control, and monitoring subcontractor compliance with traffic laws. The appellate court affirmed the trial court's ruling, concluding that TGS did not have a legal duty to control the subcontractor's driver's actions off the project site, and Metro failed to provide sufficient evidence for its negligence per se claim.

Summary JudgmentNegligenceNegligence Per SeGross NegligenceContractual DutyRight of ControlIndependent ContractorProximate CauseTraffic AccidentAppellate Review
References
33
Case No. MISSING
Regular Panel Decision

Itri Brick & Concrete Corp. v. Aetna Casualty & Surety Co.

This consolidated opinion addresses the enforceability of broad indemnification agreements between general contractors and subcontractors under New York's General Obligations Law § 5-322.1, especially when the general contractor is found partially negligent. The Court reviewed two appeals: Itri Brick & Concrete Corp. v Aetna Cas. & Sur. Co. and Stottlar v Ginsburg Dev. Corp. In both instances, subcontractor employees suffered injuries, leading to claims against general contractors who, in turn, sought contractual indemnification. The Court concluded that because the agreements sought full indemnification, even where the general contractor contributed to the negligence, they were entirely void and unenforceable under the statute. The legislative intent behind § 5-322.1 is to prevent contractors from contractually shifting liability for their own negligence, whether in whole or in part, to subcontractors, thereby affirming the public policy against such clauses.

Indemnification agreementGeneral Obligations Law § 5-322.1Subcontractor liabilityGeneral contractor negligenceConstruction project injuriesWorkers' compensation insuranceCommercial general liabilityStatutory interpretationPublic policyContractual indemnification
References
6
Case No. No. 918
Regular Panel Decision

John Martin Co. v. Morse/Diesel, Inc.

This case addresses whether a subcontractor, lacking privity, can pursue a tort claim against a construction manager for economic losses resulting from negligent misrepresentations or supervision. The plaintiff, John Martin and Company, Inc., a concrete and carpentry subcontractor, accused the defendant, Morse/Diesel, Inc., the construction manager, of providing faulty plans and negligent oversight, causing significant project delays and increased costs. The trial court initially granted summary judgment for the defendant, citing its agency status, but the Court of Appeals reversed. The Tennessee Supreme Court affirmed the Court of Appeals, ruling that a subcontractor may indeed bring such a claim against a construction manager, based on negligent misrepresentation, under the Restatement (2d) of Torts § 552. The Court emphasized that privity is not a prerequisite for such actions, and liability is limited to foreseeable use and justifiable reliance on the supplied information.

Negligent MisrepresentationEconomic Loss DoctrineConstruction LawSubcontractorConstruction ManagerLack of PrivityTort LawRestatement Second of TortsTennessee Supreme CourtProfessional Negligence
References
54
Case No. MISSING
Regular Panel Decision
Sep 05, 1996

Zeigler-Bonds v. Structure Tone, Inc.

This case concerns an appeal from an order related to a personal injury claim on a construction site. The plaintiff, an employee of an electrical subcontractor, sustained injuries after slipping on a greasy substance and falling down stairs. The initial order denied the subcontractor's motion for summary judgment but granted the general contractor's cross-motion for contractual indemnification. The appellate court modified this decision, affirming the denial of the subcontractor's motion due to remaining factual issues regarding negligence under Labor Law, but denying the general contractor's cross-motion. The denial of the general contractor's motion was based on unresolved questions of its own negligence and the enforceability of the indemnity clause under General Obligations Law § 5-322.1.

Summary JudgmentContractual IndemnificationConstruction Site InjurySlip and FallNegligenceLabor LawAppellate DivisionThird-Party ComplaintGeneral Contractor LiabilitySubcontractor Liability
References
4
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