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Case Law Database

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

Case No. MISSING
Regular Panel Decision
Mar 22, 1973

Seiger v. Port of New York Authority

Plaintiff Frank Seiger was injured when a heavy plank fell from above, striking the plank he was kneeling on and causing him to fall three stories. The court examined defendants' compliance with Labor Law § 241-a, which mandates planking at specific levels in elevator shaftways during construction. The defendants were found to have violated the statute by not having planking one story below the plaintiff and by having overhead planking three stories above. The court emphasized a liberal construction of labor laws to protect workers and upheld the trial court's judgment finding the defendants liable.

workplace injuryconstruction accidentLabor Law violationstatutory interpretationplanking requirementselevator shaft safetyabsolute liabilityworker safetynegligencefalling hazard
References
4
Case No. LAO 0778727
Regular
Sep 18, 2007

MICHAEL CHAPMAN vs. CURRAN'S CUSTOM PLASTERING, STATE COMPENSATION INSURANCE FUND

The Appeals Board granted reconsideration, rescinding the original decision that denied the applicant's psychiatric injury claim. The Board found the applicant's fall due to a broken scaffold plank constituted a "sudden and extraordinary employment condition," thus overcoming the six-month employment rule exception. The case is returned for further proceedings to determine compensability for the psychiatric injury.

Workers' Compensation Appeals BoardLabor Code § 3208.3(d)six-month rulepsychiatric injurysudden and extraordinary employment conditionMatea v. Workers' Comp. Appeals Bd.broken plankscaffold fallindustrial injurypermanent disability
References
1
Case No. MISSING
Regular Panel Decision
Apr 18, 1984

Smith v. People

Plaintiff, a framing carpenter, sustained a broken clavicle when a plank fell from scaffolding during barn renovation owned by defendant Jesus People. He sued Jesus People and Tradesmen for negligence and Labor Law violations. The trial court dismissed the Labor Law § 240 (1) claim, narrowly interpreting it to cover only falls *from* scaffolding. The jury then found no cause of action for Jesus People on other claims. On appeal, the court rejected this restrictive interpretation of Labor Law § 240 (1), holding it applies when scaffolding falls *on* a worker. The case was remitted for a new trial on liability under Labor Law § 240 (1), and Jesus People's cross-claim for indemnification against Tradesmen was reinstated.

Scaffolding InjuryLabor Law § 240(1)Workplace SafetyAppellate ReviewStatutory InterpretationFalling ObjectIndemnificationCross-ClaimProximate CauseConstruction Accident
References
8
Case No. MISSING
Regular Panel Decision

Rocha v. State

Claimant Adeline Rocha, a laborer for Mount Vernon Construction Company, sustained severe injuries on August 25, 1970, after falling from a scaffold during a bridge widening project in Westchester County. The platform, constructed by the contractor, collapsed due to a broken plank. Rocha and his wife brought an action against the State, the owner, alleging a violation of Labor Law section 240. The State challenged its liability as an owner and whether the platform constituted a scaffold. The trial court sided with the claimants, a decision affirmed on appeal. The appellate court clarified that the 1969 amendment to Labor Law section 240 imposed a nondelegable duty on owners, aligning it with sections 241 and 241-a, thereby affirming the State's liability.

Labor Law 240Scaffold CollapseOwner LiabilityNondelegable DutyConstruction AccidentStatutory InterpretationAppellate DecisionPersonal InjuryBridge WideningWorker Safety
References
7
Case No. MISSING
Regular Panel Decision

Paul v. Ryan Homes, Inc.

A painter, employed by Color Coatings, Inc., was injured at a Ryan Homes, Inc. construction site in July 2000 when an unsecured plank he used to enter a house tipped, causing him to fall. The plaintiff sued Ryan Homes, Inc. for common-law negligence and violations of Labor Law § 240 (1) and § 241 (6), with Ryan Homes, Inc. subsequently filing a third-party action against Color Coatings, Inc. for contractual indemnification. The appellate court examined whether the fall from the plank fell under Labor Law § 240 (1), distinguishing between planks used as passageways and those as functional equivalents of scaffolds or ladders. The court concluded the plank was merely a passageway, not a work tool, thus Labor Law § 240 (1) did not apply, and modified the order to dismiss that cause of action.

Labor Law § 240 (1)Elevation-related hazardUnsecured plankPassageway vs. scaffoldGravity-related accidentSummary judgmentConstruction site injuryWorker fallThird-party actionContractual indemnification
References
10
Case No. MISSING
Regular Panel Decision
Jun 11, 2008

Brownrigg v. New York City Housing Authority

The plaintiff, an elevator mechanic, was injured by a falling tool while repairing an elevator in a shared shaftway. He sued the New York City Housing Authority, alleging violations of Labor Law sections 200, 241 (6), and 241-a, primarily focusing on the lack of a vertical barrier. At the second trial on liability, the court directed a verdict for the plaintiff based on a Labor Law § 241-a violation for failing to install horizontal planking, despite the defendant's objection that planking would impede the other operational elevator. The appellate court reversed, finding the trial court improperly resolved factual disputes regarding the feasibility of planking and the worker's location, and remitted the case for a new trial on liability. The prior damages award of $660,000 will be reinstated if the defendant is found liable after the new trial.

Personal InjuryLabor LawElevator ShaftwayDirected VerdictReversalNew TrialProximate CauseStatutory InterpretationAppellate ProcedureWorkers' Safety
References
7
Case No. MISSING
Regular Panel Decision
Dec 23, 2005

Quattrocchi v. F.J. Sciame Construction Corp.

Plaintiff, a carpenter employed by Complete Construction Consortium, was injured on a construction site when wooden planks, placed by United Airconditioning Corp. employees as a makeshift scaffold, fell and struck him. The plaintiff sued Sciame, the general contractor, alleging common-law negligence and violations of Labor Law §§ 200, 240, and 241. Sciame then filed a third-party action against Complete and United. The motion court initially granted partial summary judgment to the plaintiff on his Labor Law § 240 (1) claim, but this decision was later modified. The appellate court found a triable issue of fact regarding whether the planks were adequately secured before the plaintiff’s actions, thereby denying partial summary judgment on the plaintiff's Labor Law § 240 (1) claim and otherwise affirming the lower court's order. A dissenting opinion argued that Labor Law § 240 (1) did not apply as the planks were not being hoisted or secured for the purpose of the undertaking when they fell.

Construction Site InjuryLabor Law Section 240(1)Scaffolding SafetyFalling MaterialsSummary Judgment MotionAffirmative DefenseProximate CausationAppellate ReviewThird-Party LitigationPersonal Injury
References
10
Case No. MISSING
Regular Panel Decision

Cartella v. Margaret Woodbury Strong Museum

The court reversed an order, granting summary judgment to the plaintiff, who fell from an elevated plank or scaffolding while repairing a building ceiling. The plank lacked guardrails and safety devices, which was found to be a violation of Labor Law § 240 (1). The decision emphasizes that the failure to provide necessary safety devices, regardless of the scaffold's height, constitutes a violation of this labor law section.

Scaffolding AccidentLabor Law ViolationSummary Judgment GrantedSafety Device FailureElevated WorkConstruction SafetyAppellate ReviewWorker FallGuardrail AbsenceLiability
References
3
Case No. 2019 NY Slip Op 02471 [171 AD3d 426]
Regular Panel Decision
Apr 02, 2019

Mora v. Wythe & Kent Realty LLC

The Appellate Division, First Department, affirmed the Supreme Court's order granting plaintiff Julian Mora partial summary judgment on the issue of liability under Labor Law § 240 (1). The plaintiff was injured when unsecured scaffold planks tipped. The court found that the unsecured planks were a proximate cause of the injury, rejecting the defendants' arguments that the plaintiff was the sole proximate cause of his accident or that a recalcitrant worker defense applied. The decision emphasized that a statutory violation serving as a proximate cause precludes the plaintiff from being solely to blame.

Scaffold AccidentLabor LawSummary JudgmentLiabilityProximate CauseRecalcitrant WorkerAppellate DecisionConstruction SafetyWorker InjuryUnsecured Equipment
References
2
Case No. MISSING
Regular Panel Decision
Dec 21, 2006

Claim of Cushion v. Brooklyn Botanic Garden

Claimant, an employee of Brooklyn Botanic Garden, sustained an injury after falling on a broken sidewalk in a public parking lot adjacent to her workplace while commuting home. Initially, a Workers' Compensation Law Judge established the case as a work-related injury, but the Workers' Compensation Board reversed this, concluding the injury did not arise out of and in the course of employment. The appellate court affirmed the Board's decision, reasoning that the risk of injury from the broken sidewalk was not a "special hazard" but a risk shared with the general public, thus falling outside the compensable "gray area" of the going and coming rule.

Workers' CompensationAccidental InjuryCourse of EmploymentArising Out of EmploymentGoing and Coming RulePublic Parking LotOff-Premises InjurySpecial HazardGray Area DoctrineSidewalk Fall
References
5
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