DaSilva v. Haks Engineers, Architects & Land Surveyors
Plaintiff Paulo DaSilva, a construction worker, was injured after falling from a scaffold while working on the Croton Falls Dam project. He brought an action alleging violations of Labor Law §§ 200, 240 (1), and 241 (6) against Haks Engineers, Architects and Land Surveyors, P.C., Earth Tech Northeast, Inc., and Haks Et Joint Venture, who were construction managers for the project. The Supreme Court, New York County, granted defendants' motions for summary judgment, finding that under their construction management services contract, defendants did not have supervisory control over the construction methods and were not statutory agents for liability under the Labor Law sections. The Appellate Division, First Department, unanimously affirmed this decision, stating that general supervisory duties were insufficient for liability and that plaintiff failed to present evidentiary support to contradict the contract terms or suggest that further discovery would yield relevant evidence.