Husted v. Central New York Oil & Gas Co.
Plaintiff Donald Husted, an employee of Collins & Walton Plumbing & Heating Contractors, Inc. (C&W), was injured after falling into an unguarded hole at a gas storage facility owned by Central New York Oil and Gas Company, LLC (CNYOG). The hole was drilled by Mateo Electric Corporation and allegedly obscured by G. Webster, Inc. Husted and his wife sued CNYOG, Mateo, and Webster for negligence and Labor Law § 200 violations. CNYOG sought indemnification from Mateo, Webster, and C&W. The Supreme Court initially dismissed plaintiff's claims against CNYOG and granted conditional indemnification to CNYOG against Mateo and Webster, while denying it against C&W. The Supreme Court also dismissed CNYOG's third-party complaint against C&W. On appeal, the higher court modified the order, reversing the dismissal of plaintiff's claims against CNYOG, reversing the conditional indemnification against Mateo and Webster, and reversing the dismissal of CNYOG's third-party complaint against C&W. The court found that CNYOG failed to prove it lacked constructive notice of the dangerous condition and that questions of fact remained regarding its negligence, making summary judgment on indemnification premature.