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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

Haughton v. T & J Electrical Corp.

Plaintiff Archebald C. Haughton, Jr., a maintenance worker at Hudson Valley Community College, suffered severe injuries from electrocution while attempting to restore power during an outage. Despite knowing that the power company, Niagara Mohawk, was assembling a crew, plaintiff's supervisors directed him to work on high-voltage equipment in a dark and smoky room, without proper protective gear. Plaintiff and his wife sued Niagara Mohawk and T & J Electrical Corporation, an electrical contractor, alleging breach of duty of care. The Supreme Court granted summary judgment to the defendants, concluding that the actions of the plaintiff and his supervisors constituted an unforeseeable intervening act. The Appellate Division affirmed this decision, absolving the defendants of liability.

Summary JudgmentProximate CauseIntervening ActElectrocutionWorkplace AccidentHigh VoltageDuty of CareNegligenceAppellate ReviewEmployer Liability
References
8
Case No. MISSING
Regular Panel Decision

International Union of Electrical, Radio & Machine Workers v. Westinghouse Electric Corp.

The plaintiff Union filed a motion for summary judgment seeking to compel arbitration of twelve grievances against the defendant company. The defendant had refused arbitration, arguing that the grievances were nonarbitrable under exclusionary clauses in their collective bargaining agreement. The court, applying principles from the Steelworkers cases and Carey v. General Electric Co., determined that the agreement's exclusionary clauses limited the arbitrator's award-making authority but did not strip them of jurisdiction to hear the grievances. The court also rejected the defendant's ancillary arguments regarding laches, NLRB exclusive jurisdiction, and potential unfair labor practices. Consequently, the court granted the Union's motion, holding all grievances were subject to arbitration.

Collective Bargaining AgreementArbitrationGrievancesSummary JudgmentLabor LawContract InterpretationArbitrabilityExclusionary ClausesAward-Making AuthorityJurisdiction
References
7
Case No. MISSING
Regular Panel Decision

Baywood Electric Corp. v. New York State Department of Labor

Baywood Electric Corporation, an electrical contractor, initiated a CPLR article 78 proceeding to challenge a final order from the Commissioner of the New York State Department of Labor. The Commissioner had determined that Baywood willfully violated Labor Law § 220 by failing to pay prevailing wages and supplements on a public works contract with the Town of Babylon, imposing back wages, interest, a civil penalty, and debarment. Baywood contended its due process rights were violated by the denial of an adjournment for the administrative hearing and that the willfulness finding lacked substantial evidence. The reviewing court rejected these arguments, affirming the Commissioner's determination and dismissing Baywood's proceeding, finding ample opportunity for counsel and substantial evidence of willful violation based on Baywood's experience and prior similar conduct.

public worksprevailing wage lawLabor Law § 220CPLR article 78due processadministrative lawwillful violationelectrical contractorcivil penaltydebarment
References
8
Case No. MISSING
Regular Panel Decision

Harris v. Metropolitan Life Insurance

Plaintiff Morgan Harris, Sr., sustained injuries after slipping on a construction site and initiated a lawsuit against Lehr Construction Corporation. Subsequently, Lehr filed a third-party action against Forest Electric Corporation, the plaintiff's employer, seeking common-law indemnification. Forest moved for summary judgment, contending that Harris did not suffer a "grave injury" as defined by Workers' Compensation Law § 11, which would bar Lehr's indemnification claim. The court clarified the burden of proof for "grave injury" in summary judgment, stating that the movant (Forest) must first establish the absence of such injury. As Forest failed to provide prima facie evidence, its motion for summary judgment was denied. Lehr's cross-motion to amend its complaint to include a claim for failure to procure insurance was denied, while its request to add a claim for contractual indemnification was granted. Lehr's motion for summary judgment on its indemnification claims was deemed premature and denied.

summary judgmentgrave injurycommon-law indemnificationcontractual indemnificationthird-party actionburden of proofconstruction site injurymedical evidenceamendment of complaintemployer liability
References
8
Case No. MISSING
Regular Panel Decision

Stilsing Electric, Inc. v. Joyce

Plaintiff, an electrical contracting corporation, initiated a defamation action against the defendant, a business manager for IBEW Local Union No. 724. The defendant had investigated the plaintiff's apprenticeship program, believing it was non-compliant with state labor laws and regulations. He filed complaints with the State Department of Labor, leading to an administrative hearing. Although an initial review found the plaintiff's program compliant, the defendant's persistence led to a formal hearing where the Commissioner of Labor ultimately dismissed the defendant's complaint. The plaintiff then sued for defamation, alleging that the defendant's written and oral statements during this process led to loss of contracts with Albany County. Special Term denied the defendant's motion for summary judgment, ruling that he was, at best, entitled to a qualified privilege and that issues of fact regarding malice existed. On appeal, the court determined that the administrative proceeding was quasi-judicial, based on its adversarial nature, reliance on law and facts, and susceptibility to judicial review under CPLR article 78. Consequently, the court concluded that the defendant's communications were protected by an absolute privilege, thereby reversing Special Term's orders and dismissing the plaintiff's complaint.

DefamationAbsolute PrivilegeQualified PrivilegeAdministrative LawQuasi-Judicial ProceedingsLabor Law ComplianceApprenticeship ProgramsFreedom of ExpressionPublic Policy ArgumentsSummary Judgment Motion
References
11
Case No. MISSING
Regular Panel Decision

International Brotherhood of Electrical Workers, Local 97 v. Niagara Mohawk Power Corp.

This case involves a dispute between International Brotherhood of Electrical Workers, Local 97 (the union) and Niagara Mohawk Power Corporation. The union sought to confirm an arbitration award that reinstated employee Patrick J. Rando, who was discharged by Niagara Mohawk after adulterating a drug test sample and later testing positive for cocaine. Niagara Mohawk counterclaimed to vacate the award, arguing it violated public policy related to nuclear safety. The employee, a Chemistry Technician at a nuclear power plant, had unescorted access to critical areas. The court reviewed the public policy implications de novo, citing NRC regulations (10 C.F.R. Part 26) that emphasize strict adherence to nuclear safety rules and the trustworthiness of personnel. The court found that the grievant's conduct directly contravened this well-defined public policy. Consequently, the court denied the union's motion to confirm, granted Niagara Mohawk's cross-motion, and vacated the arbitration award, dismissing the complaint entirely. Both parties' requests for attorney's fees were denied.

ArbitrationPublic PolicyNuclear SafetyDrug TestingEmployee DischargeCollective Bargaining AgreementDue ProcessTrustworthinessReliabilityReinstatement
References
28
Case No. MISSING
Regular Panel Decision

General Electric Co. v. M/V Gediz

General Electric Company brought an action against Turkish Cargo Lines under the Carriage of Goods by Sea Act (COGSA) for alleged cargo damage. Turkish Cargo Lines moved for summary judgment, asserting that General Electric's claim was barred by COGSA's one-year statute of limitations. General Electric contended that Turkish Cargo was estopped from raising this defense due to its conduct, which supposedly induced General Electric not to file suit within the required period. The court conducted a hearing to assess the validity of the estoppel claim. Ultimately, the court found that General Electric failed to demonstrate sufficient conduct by Turkish Cargo to warrant an estoppel, noting that claimed extensions were invalid or made by unauthorized agents. Consequently, Turkish Cargo Lines' motion for summary judgment was granted, and General Electric's complaint was dismissed as time-barred.

COGSAStatute of LimitationsEstoppelSummary JudgmentCargo DamageMaritime LawShipping DisputeAgent AuthoritySettlement NegotiationsTime Barred
References
10
Case No. 2011 NY Slip Op 31057(U)
Regular Panel Decision
Apr 26, 2011

Fiorentino v. Atlas Park LLC

The case involves a plaintiff who sustained an electric shock injury while working on a construction project in Queens. The plaintiff, an employee of Donaldson Acoustics, Co., was installing ceiling tiles when he grabbed a dangling BX electrical cable and was shocked. He initiated a personal injury action against Atlas Park LLC (owner), Plaza Construction Corporation (general contractor), and Sage Electrical Contracting, Inc. (electrical subcontractor), alleging violations of Labor Law §§ 200, 240(1), 241(6), and common-law negligence. The Supreme Court initially dismissed Labor Law § 200 and common-law negligence claims against Atlas and Plaza, and conditionally granted Atlas's and Plaza's motions for contractual and common-law indemnification against Sage and Donaldson. The court also denied Donaldson’s motion for common-law indemnification against Sage. On appeal, the court modified the lower court's order. It unconditionally granted Atlas’s and Plaza’s contractual indemnification claims against Sage and Donaldson. It also granted Donaldson’s motion for common-law indemnification against Sage, while denying Atlas’s and Plaza’s common-law indemnification claim against Donaldson, citing Workers’ Compensation Law § 11. The decision was otherwise affirmed.

Personal InjuryConstruction Site SafetyElectrical HazardIndemnification ContractThird-Party ActionAppellate DivisionSummary Judgment MotionSubcontractor ResponsibilityVicarious LiabilityWorkers' Compensation Exclusivity
References
8
Case No. MISSING
Regular Panel Decision

United Electrical, Radio & MacHine Workers v. General Electric Co.

The Union, consisting of United Electrical, Radio and Machine Workers of America and five of its locals, sued General Electric Company under the Taft-Hartley Act to compel arbitration of various grievances. Both parties filed motions for summary judgment. The central issues revolve around whether the 1956-1960 collective bargaining agreement provides for compulsory arbitration and if the grievances fall within its scope. The court found the contract language ambiguous, requiring extrinsic evidence for proper interpretation. Consequently, the court denied both motions for summary judgment, citing the presence of genuine issues of material fact that warrant a full trial.

Collective Bargaining AgreementArbitrationTaft-Hartley ActSummary JudgmentLabor LawContract InterpretationExtrinsic EvidenceAmbiguityFederal Rules of Civil ProcedureGrievance Procedure
References
22
Case No. 2017 NY Slip Op 02888 [149 AD3d 500]
Regular Panel Decision
Apr 13, 2017

O'Leary v. S&A Electrical Contracting Corp.

Plaintiff Patrick O'Leary sustained injuries from an electrical shock while overseeing renovation work. He sued S&A Electrical Contracting Corp. and 1435 Broadway, LLC (Owner) under Labor Law § 241 (6). The Supreme Court granted O'Leary partial summary judgment on liability, denied Owner's motion to dismiss, and denied Nygard's motion for summary judgment. The Appellate Division modified the Supreme Court's order, granting Owner summary judgment on its contractual indemnification claim against Nygard International Partnership and dismissing all claims against Nygard NY Retail, LLC, while otherwise affirming the lower court's decision. The court found that O'Leary was engaged in construction work, a violation of 12 NYCRR 23-1.13 (b) (4) occurred due to negligence, and New York law governed the third-party claims.

Construction accidentLabor Lawindemnificationsummary judgmentvicarious liabilityelectrical shockpremises liabilitythird-party claimschoice of lawcomparative negligence
References
9
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