DeMaria v. RBNB 20 Owner, LLC
This appellate decision modifies and affirms prior orders regarding a construction site accident where the plaintiff was injured by a sprinkler pipe and alleged inadequate lighting. The plaintiff's injuries led to claims of common-law negligence and violations of Labor Law §§ 200 and 241(6) against multiple defendants, including Linden Construction Corp., Forest Electric Corp., owner defendants, and Newmark Construction Services, LLC. The court granted Linden summary judgment on common-law negligence and Labor Law § 200 claims, finding it did not directly create the hazard or have notice, but denied it for Labor Law § 241(6) due to its role as a statutory agent through its sub-subcontractor, Tower Interior Corp. Forest's motions for summary judgment on all claims were denied due to unresolved issues of fact regarding inadequate lighting and notice. The owner defendants were granted summary judgment on common-law negligence and Labor Law § 200 claims, but Newmark, the construction manager, was denied summary judgment on those claims because of a dispute regarding its notice of the inadequate lighting. Furthermore, summary judgment for contractual indemnification claims was largely denied for all parties, as triable issues of fact remain regarding the respective liabilities of Linden's sub-subcontractor and Forest's role in the inadequate lighting.