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Danger Everywhere: Labor Law and Construction Accidents

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Danger Everywhere: Labor Law and Construction Accidents

The nature of construction sites frequently results in hazardous and dangerous conditions for the workers. In an effort to protect them, several state statutes govern site conditions and instill requirements for safe operations relative to the performance of the work. In New York, among these are Labor Law Sections 200 and 241(6), which cover virtually every conceivable type of activity that occurs in connection with construction projects. This course will review the requirements of these statutes and what entities are subject to their mandates. Also discussed will be how the requirements of these laws are implemented in the field, including their interplay with the industrial code, and the defenses that are traditionally raised when a worker is injured due to claimed violations. Real life examples will be utilized to illustrate the principles and explain how the case law interprets the same.

Transcript

Uh, good afternoon, everyone. Thanks for joining us. My name is David LoRe. I'm a I'm a partner with Milber Makris Plousadis & Seiden. I'm one of the team leaders of the Labour Law Practice Group. I practice out of Woodbury, New York, on Long Island. I've been defending labor law and construction accident claims on behalf of insureds and construction contractors and property owners for close to 20 years now. And it's what I primarily do on a day to day basis. My partner, Russell McBrearty, was tied up in court. He should be joining us soon to complement my part of the presentation. And with that as an introduction, why don't we get going? Um, in part one of the presentation we covered mainly the impact of Labor Law 240 subsection one in relation to construction accident claims. And just as a brief recap, that statute is implicated in connection with accidents that involve elevation differentials and the effect of gravity either on the worker or on an object at the site resulting in an accident. We reviewed situations where claims could be brought in what we call a falling worker scenario, where the worker falls from an elevated surface such as a ladder or a scaffold. We also reviewed the scenarios where workers are injured because of the effects of gravity on falling objects or objects that fall. Some of the common examples were workers at ground level where work is taking place above their heads at another level, and whatever some mishap occurs and an object or an item falls and strikes them. Those were the two broad categories. And of course there's nuances which we reviewed within each, but those were the two broad categories covering labor law 240. Now, by its very definition, those categories are somewhat limited in that we're only looking at situations where gravity is implicated and either the worker falls or an object falls. Today, we're going to open it up a bit. We're we're going to look at two of the other major labor law statutes that are involved in construction accident litigation. And these are labor law, Section 200 and labor law, section 241, subsection six. These are the other two big ones. When there's an accident at a construction site that leads to a lawsuit in New York, there are typically four causes of action. Pled the first we covered last week, the labor law 240 claim. The other three are these two sections, 200 and 241 six and then one that's not based on a statute but derives from the common law, and that's the claim for common law negligence. So those four different causes of action comprise the vast majority of complaints in New York labor law litigation when there's a construction accident. Now, as I mentioned a moment ago, Sections 200 and 241 six are much broader. And they encompass scenarios that that are much broader than than the elevation related differentials and dangers that we reviewed last week. These laws have been developed by the New York legislature over the years, just like with labor Law 240. They came into their current form in the late 1960s after a lot of back and forth between the plaintiffs lobbying plaintiff's side of the bar, the lobbying groups on their end, and the defense side, which involved the construction contractors and commercial and primarily commercial property owners. Once those laws were in place in their current form, over the past 50 years or so, they've been modified, shaped, nuanced and crafted by the case law that's been promulgated by the appellate courts of New York, the top court in New York being the Court of Appeals and the intermediate appellate courts of New York being what we call the appellate divisions. Those are the courts over the years that have really given teeth to these laws and shaped them into the forms that we recognize them today and which control safety conditions at construction sites. And that's really what this is all about. These laws exist with their goal being to provide construction workers with safe working conditions and safe working environments at construction sites. Now they we'll get into it, but they encompass really just about everything you can imagine taking place at from the from the lowest level construction sites, perhaps a contractor working on a minor alteration or change to a home to the building of skyscrapers in the heart of the downtown of a city. So let's get into it with that is an introduction. Here's here's just basically the broad overview of what I just mentioned, the three sections of the New York Labor. The law. And when claims are brought, when there's a construction accident and a complaint is filed and a lawsuit begins, as I mentioned, we have these four causes of action. The three ones you see here are the statutes that the causes of action are based on. And we simply refer to these as the statutory causes of action. The fourth I mentioned a moment ago is the companion common law negligence claim, which we'll get into in a little bit. Okay. The first statute that we're going to discuss today is New York labor law, section 200. And again, broadly speaking, this the goal of this statute is to provide workers with a safe place to work. Um, and it's really a general statute. It involves addressing really any type of condition at a work site that can be hazardous or unsafe. And, you know, it doesn't even only have to apply to construction accidents. That's that's the context that we're talking about it today in. But labor law 200 is applicable to really all work environments across New York State. You know, it doesn't have to be necessarily limited to the construction context, but that's where we see it the most, because frankly, that's where most workers who are injured on the job get hurt. Um, now last week we talked a little bit about the basic framework of the parties to a average construction site in New York and the relationships of those parties generally speaking, we have the property owner that could be the owner of a skyscraper, that could be the owner of a modest building, that could be the owner of a 1 or 2 family residential home. We have the general contractor at the site. Generally, the general contractor is the party that's hired by the owner to construct whatever it is that's being built. The general contractor generally hires subcontractors to perform the work of the different trades the plumbers, the electricians, the carpenters, the Hvac workers, all of the different types of work that go into building of whatever the project is. The general contractor typically also coordinates and generally oversees the the progress of the construction and keeps an eye on things and reports back to the owner. Last week we differentiated the general contractor from another entity which we labeled the construction manager, and we looked at some of the nuanced differences between those two types of entities and the resulting implications for those entities. Under what we talked about last week was Labor law 240. A lot of that is going to be similar for Labor law, 200 and labor law 241 six. And now labor Law 200 and I'll just read it here. Labor law Section 200 is a codification of the common law duty. Imposed upon an owner or general contractor to provide construction site workers with a safe place to work. Now, what they mean by that, the codification of the common law duty is before labor law. 200 came about in the late 60s. There was a law and there was laws in place to protect workers at sites. But they weren't codified. They weren't codified. I'm sorry. In the New York in New York law, they were based on the common law, which was basically just saying negligence, basically at common law. The owners and the folks who ran construction sites had a duty and an obligation to keep those sites safe for the workers who were present and working there. But there was no actual law on the books, the official books of the legislature of New York until the late 60s, when the those common law principles, the duty of the owner and the GC to keep sites safe were put officially into black letter law. With the passing of labor law 200. Now when there's an accident at the site, one of the key questions to ask is who? Who was responsible for the work that led to the accident? Who was responsible for the whatever the injured worker was doing at the time, who was responsible for the conditions that may have resulted in the accident? You know, again, just like we talked about last week, we have to look at the relationships of the parties. Basically, what the second part of this slide is showing is that. In order to be held liable under Labor law 200, you first have to be in the category to which it applies. And over the years, the case law has evolved to to say that the folks who can be on the hook for labor law 200 liability are those who have authority over the work conditions which led to the injury. A lot of times that could be the general contractor who is controlling the work going on at the site. A lot of times that's the general contractor who might have control over the site and the ability to correct or avoid unsafe conditions at the site. Basically, the legislature wants to put the burden of a safe work site on those they deem in the position to have the most influence over the site itself and to be able to correct or avoid whatever might be deemed hazardous or dangerous to the workers. So the first question you got to ask is, well, who am I representing? Who is our insured? Are we the owner or are we the general contractor or are we a subcontractor at the site? Are we the employer of the injured plaintiff or the injured worker? Because that has its own special category of of conditions and elements that we'd have to look at? Basically, we have to determine who who is going to be on the hook for, first of all, who is responsible for a safe work site and who's going to be on the hook in case there's a violation and an injury. If if if we look at the law itself, the the owners in general, contractors are generally going to be folks considered in that chain in that line. Um, they you know, generally are the folks who can control things at the site the most. In fact, lots of times owners and general contractors will hire an outside site safety consultant or a site safety contractor who will come in and be their eyes and ears. Um, we also have to look at a special category of folks called agents. Now, we went over a lot of the agency law last week in terms of in connection with the labor law 240 discussion. The same general rules apply under Labor law 200 a court is going to look at if a parties who may not be the owner or the general contractor at the site, but they're going to look at parties who may have control over not only the injured workers work, the things that the worker was doing at the time of the accident, But they're going to look at whether or not a party had control over the site conditions, the environment or whatever it is, whatever hazard it is, that may have resulted in the accident. So a large part when it's not cut and dry, when you're not the owner or the general contractor, but instead you represent or ensure a separate contractor, let's say a carpentry trade or an electrical company. One of the things we wrestle with the most is determining whether or not that trade had control over either the injured workers activities or the site conditions. Now, in the old days, it used to be a little easier. The courts were a little more narrow in describing who could be an agent. They would basically deem an agent those entities who had control over the work activities of the injured worker, literally the person who was injured, what that person was doing at the time. And a lot of times that came down to the injured workers employer who might have other defenses that we can talk about later, or perhaps a what we call a mid-tier contractor. For example, if a GC hires an Hvac company and that Hvac company sub subcontracts out a portion of its work to another company, let's say another company who employed the worker who ends up getting injured, that mid-tier contractor could end up being deemed an agent because a court will determine that that mid-tier contractor had control over the injured worker and the injured workers activities because it was in that chain of contracting and employment. And as I mentioned, one of our main tasks at the outset of a file and as Discovery continues, is to really try to get a grip on whether or not our client had the type of control over the work activities of the injured plaintiff so as to make an an agent and thus be subject to liability under the Labor law. Now, I mentioned that was the old days that was a little more narrow. The trend in the case law currently is to expand that and it's a negative for defendants. It's making more and more contractors who are not the GC. It's making more and more contractors be deemed agents and thus have more exposure under the labor law, have more responsibility and perhaps liability exposure because the law has expanded to deem those not only with contract or not, perhaps not at all with control over the work activities of the injured worker, but more broadly, perhaps control over an area of the site or control over certain work activities that created the conditions which led to the injured. Workers accident. Now we see that typically, let's say an electrician. Let's let's let me back up. Let's say an Hvac worker is on a ladder hanging hangers or installing hangers to eventually hang a pipe and duct system. And that injured worker and that Hvac worker accidentally comes into contact with a live wire. That's not part of his work. That happens to be in the ceiling for whatever reason. We're frequently seeing the unrelated trades being brought in and being deemed agents because let's say the electricians, let's take them, let's take them as an example. If the electricians had worked in that area the week before or two weeks before and had arguably or perhaps allegedly left some form of electrical shock condition in that ceiling, and later on, an Hvac worker came and was exposed to it and got shocked. We're seeing situations in this example, at least, where the electrical trade, despite having no connection to the injured Hvac worker, could be on the hook as an agent for the purposes of the labor law because it had worked in controlled and arguably or allegedly created the conditions which led to the accident. So the practical tip to take away from this is, you know, you get a new claim, you look at your insured or we look at our new client and we say, well, he's the owner of the site or that company is the GC. We're not going to be deemed and we're not the employer of the injured worker. We're going to avoid being deemed an agent for the purposes of the labor law. Unfortunately, the way the law is going, it doesn't stop there. We now have to really look at what we were doing. We have to look at the location and the site conditions specifically in connection with the accident and ask the question of did we do the work that led to this this person being injured? And it opens up a lot of exposure and liability. So that's really the first thing I look at, at least when I get a somewhat gray case where I'm not the owner of the GCA first, determine who I am in the chain and whether I'm going to have exposure under the labor law and in particular, labor law 200 as we're talking about here. All right, next slide. Now, the courts have evolved the case law or developed the case law into defining the elements of what makes up a labor law 200 claim. Now, basically, at its core, labor law 200 claim is simply an allegation that the defendants, whoever those are, the owner, the GC and their agents, violated their duty, their duty at common law, which is now codified in labor law 200 to provide their workers a safe place to work. And that violation led to to the injury which results in the lawsuit. Now, the courts have taken a look at this law, and they've determined over the years that accidents and claims under labor law, 200 and under the common law, negligence or under negligence principles generally fall into two broad categories. The first are accidents which arrive from arise from a defective or dangerous condition on the premises, which is generally just synonymous with worksite. And number two, those types of accidents and claims which arise from the manner in which the work was performed. Now, each of these have different elements and have different burdens of proof and have different implications for the different defendants who are being sued and those who work at the site. Let's take them in turn. Worker gets injured at the site. How does it happen? First question we have to ask now, it could be black and white or it could be grey. I call the grey ones hybrids, which we'll discuss in a moment. The easiest, the easiest conceptual conceptualization of number one, which I call the dangerous condition cases, are when a worker gets injured because of something that exists at the site, such such as a tripping hazard, you know, the proverbial banana peel, the taut electrical cord that the worker trips over, which should never have been where it was. The snow and ice, snow and ice is another typical one. We see plenty of plenty of work takes place in outdoor environments or exposed environments, and the workers are exposed to the elements and the work site is exposed to snow and ice and even even rain, which can create slippery conditions. Basically the same types of things we see in premises liability cases apply here. And when a worker is injured as a result of of something like that, let's say a worker trips over a stray electrical cable. These these sites, you got to remember, can be very chaotic. You just walk by any site, you know, you'll look past the blue plywood construction wall and you'll see a lot of a lot of chaos back there. And guys leave stuff and workers leave. Stuff is benign as as, you know, as lunch boxes, if that's still a term these days and it may not be as obvious as an electrical cable, not where it should be, but, you know, people get hurt. Workers get hurt at work sites just like they do in other premises, liability situations. And we call these dangerous condition cases. Now in a dangerous condition case. There's even under that umbrella. Under number one, there's still elements that a plaintiff has to prove in order to succeed on such a claim for owners and general contractors. Basically, the plaintiff has to prove the same elements in a dangerous condition case that the that the plaintiff has to prove in a typical premises liability case. They have to prove either that the owner or the general contractor or their agent, which I just went over, was had either created or caused the dangerous condition or was on actual or constructive notice of the condition. This may actually be another slide. I'm sorry I got ahead of myself, but we'll take it from here. Uh, and yet failed to do it. To do anything about it, yet failed to correct it. Now. This is relatively rare to find liability on an owner or a general contractor. Not not unheard of, but relatively rare because it's very normally the conditions at sites which can be deemed dangerous or hazardous. They're actually caused by the subcontractors. Typically, the general contractor doesn't actually perform much hands on labour at the site. They could have labourers sweeping up that type of thing, but typically the actual work is performed by the by the subcontractors. And the side effects and fallout from that work can be the creation of debris, can be the creation of trash, can be the creation of conditions which can lead, which can be deemed dangerous and lead to accidents. So a lot of times we're able to defend dangerous condition cases under labour law 200 against owners and general contractors by pointing out that no one had ever made complaints to either one of them about the condition they had. In other words, they had never received actual notice. They certainly didn't cause or create the condition. They didn't they didn't leave the electrical cable in a spot where it wasn't appropriate. They didn't, you know, drop the proverbial banana peel on the floor. Et cetera. Et cetera. So typically, those claims are a little a little easier to demonstrate. And we can point to a sub I'm sorry to defend and we can point to a subcontractor, um, having created the actual condition, that's I would say that the vast majority of my claims involve conditions that are that result from the work of the subcontractor. Um, now it can get a little tricky in terms of constructive notice. And that's, that's the one pitfall for this kind of things. Let's say you have, let's say you have a scenario. I'll give you I'll give you a practical example. I have a claim where I'm represents the owner and the general contractor of a relatively large scale condominium complex construction, the construction of a condo complex here in Nassau County, Long Island. And the GC hired the various trades that I described before to perform the work. One of them being the electrical trade, another being the plumbing trade. Now the injured plaintiff who was an employee of the electrical subcontractor, he claims that as he was moving some electrical equipment down a staircase in one of the buildings under construction, he stepped on and tripped over a what ended up being a stray piece of cut plumbing pipe, which, for reasons completely unknown, somehow was sitting on the step in this stairwell. Now, this is not uncommon at a site. You know, trash gets strewed all over, you know, debris gets placed where it shouldn't be. But in this particular case, he tripped over the piece of plumbing pipe. And it is undisputed that both the electricians were working in the building at the time and also the plumbers were working in the building at the time. It was further undisputed that the only company on site that that used this particular type of pipe called a Pex picks were the plumbing contractors. So it should be easy to say that, you know, they created it. My client, the GC, had nothing to do with it. No, I'm having a problem on this case because the plaintiff is alleging that while we the GC, may not have caused or created the condition and may not have been on actual notice of it, in other words, you know, no complaints were ever made that anyone knows about. My client was on constructive notice of it. And what that means is in practice, it means that the condition here, the pipe, may have existed for such a long period of time that my client, the GC, in performing some of its other duties at safety duties, its inspection duties, should have discovered it and remedied it in the normal course of business, but did not. So, you know, I'm dealing with this claim and the case law is pretty clear that I have to jump through a pretty high burden. And this actually leads to a practical tip that I counsel my clients on all the time. The case law says that in order for me to defeat such a claim, I have to demonstrate with specific evidence. When the last inspection of that area was made by my client. I have to actually go out and put forth some evidence. And I thought I did it with with deposition testimony as to when my. My client's employees last performed one of their site sweeps or their inspections or their check of these buildings to make sure there were no hazards like this in any of the areas that could lead to an accident. And I thought I did it. But, you know, courts are unpredictable. And the court said my my evidence, which was the deposition testimony of one of the foreman for my client who supervised the crew of workers that specifically did this, I thought I put in perfect evidence. I thought his deposition testimony satisfied my burden to a t that the site that the stairwell in question had been inspected. Um, I think it was an hour before the accident was claimed to have happened. But the the court denied that and kept plaintiff's labor law 200 claim alive based on my failure to demonstrate lack of constructive notice. And it was, it was a little surprising because I thought I had done it. Um, but the takeaway from this is, in an ideal situation, we'd be presenting evidence that in my case, unfortunately, I didn't have, I would have been able to present written work records, work daily logs, work logs showing exactly when those site inspections were conducted. And, you know, if you were to go up, the guys on the site and say, did you keep a record of when the last time you inspected, you know, a particular sterile was, you'd probably be laughed out of the building? They would say it's just not practical. We're we're looking at that stuff all day long. But this is a practical moment where where I can't get the claim dismissed. Maybe a jury will dismiss it one day if the case doesn't settle. But I couldn't do it because I just simply didn't have this documentation that the client did not keep such records. So I always counsel my my construction clients, no matter how laborious it seems or how mundane. Please try to document everything, including something as as important under our case law as site inspections. That's just one one practical example from my my day to day world. But typically, those are the elements that we have to plaintiff has to prove, and the property owner or the general contractor or their agents have to demonstrate the absence of in a dangerous condition case. Now, there's other things. There's other defenses that maybe the condition is not inherently dangerous. Maybe it's open and obvious. Maybe it's what we call de minimis under the law, like like, you know, a pebble that that a injured. I have a case involving that where an injured plaintiff claims to trip over a pebble. These are all types of things that you can argue are not actually dangerous, not inherently dangerous. And through the use of Mr. Workers or Mrs. Workers own senses should have been observed and avoided. The other broad category under Labor law, 200 that the courts have deemed accidents actionable under this statute are those arising from the manner in which the work was performed. And this is another way of saying we we use the synonym or the euphemism. Means and methods case. So in other words, the means and methods of how work was performed. Um, at which. Which. And that work resulted in an accident. Now, basically, we have to go back. This is a common theme in labor law litigation. We have to go look at who had authority over the work which led to the accident. Usually we. This is a common fact pattern. We have a tradesman, a worker for the one of the subcontractors, you know, an electrician, a plumber, an Hvac worker. We have them somehow getting injured as a result of the manner in which they're performing their work. Now, this this typically is not a dangerous site condition. This is actually they were using a piece of equipment that perhaps malfunctions and injures them. They were performing work in a manner in which it shouldn't have been or a manner in which they were told not to. Basically, anything that they're doing in terms of the way they're performing the work, which leads to an injury. And when a plaintiff brings those when a when that kind of accident happens and a plaintiff brings a labor law, 200 claim against an owner or a general contractor, the first inquiry is is the redundant one I've been talking about for for almost two sessions now. We look at whether or not our client had authority over the work activities of that subcontractor. That's the critical inquiry. Now, there are some differences in between the different appellate courts of New York with respect to how strict they are with respect to that. But generally speaking, if a owner or general contractor has authority over the means and methods of how work is actually performed, use that type of hammer instead of that one, etcetera, they can be on the hook for an accident involving those means and methods, even if they had nothing to do with the work itself, Even if the work itself was done solely by the subcontractor and the workers from that subcontractor. Um, now there's a little bit of a controversy here in at least between two of the different appellate division departments in New York in the second department, which covers Long Island, Brooklyn and Queens, a huge jurisdiction involving thousands upon thousands of construction accident claims. It's a little harsher on defendants. The second department says that a general contractor or an owner can be on the hook under a means and methods analysis if they merely had authority over the work activities of the subcontractor. Even if the owner and GC did not actually supervise or get involved with that work. So if the owner of GC has authority, perhaps through the contract documents, perhaps through some other evidence, that they actually could control those, even if they didn't do it, they could be on the hook under a means and methods analysis. The first department is a little more lenient on defendants that the first department covers Manhattan in the Bronx, which again, huge jurisdiction that wasn't upon thousands of construction accident cases. The first department takes a little more lenient approach and says that if an owner in GC is going to be on the hook for the means and methods analysis of Labor Law 200, they not only have to have the authority over the work, they had to have actually been involved in it. They actually had to have actively supervised it or actively directed it. Um, now there's a few cases going back, and this tells you a little bit about how factually specific these cases are and how lawyers and the courts are still grappling with this stuff. Even in the second department, you can kind of wiggle your way out of it because there are some cases that say the owner and GC not just have to have authority, but have to actually be involved in the work. But it's a little more difficult. Their first department's a little more lenient. But, you know, when, when we when we fight these claims, we basically have to throw all the mud we can against the wall and hopefully judge will agree with something we're saying. But, you know, as a practice tip, at least in New York, under labor law 200, it's important to be aware of the differences in the departments and and to really research the case law in the appellate division department that's applicable to your case and therefore your client and what the requirements are. Um, now, here's a major caveat to the means and methods analysis. I just got through telling, I just got through telling you that a, that a general contractor can be on the hook under a means and methods analysis of labor law 200 if it merely had authority over the work practices of the subcontractor. Here's the major caveat. If the GCC just has a general, what we call general supervisory power, or the ability to generally monitor the site, generally coordinate the different trades at the site and make sure they're working in harmony and generally oversee safety practices, including importantly, the ability to stop any unsafe work practices that are observed. While those powers are great and show that the GC is is taking active supervision of the site. The courts have held that such general supervision over the progress and the timing of the work and the general safety practices that safety practices at the site. Those that type of authority is not enough to rise to the level of liability and exposure under Labor law. 200 in a means and methods accident. In other words, to get to that level, it has to go beyond that. The GC has to actually have authority over the specific manner in which work is being performed. Now, a lot of the older general contract contracts that are still used in the industry and relied upon, I don't even think anybody reads them anymore. But there are dozens of pages of boilerplate provisions. One of them buried deep within, you know, deep within page 42, you know, subsection 6.2. I'm just making that up just to show you how obscure it is. Generally has a sentence saying that the GC will be responsible for the means and methods or the means and manners of manner of how the work is performed. And I see way too many of our clients and your insureds or insureds in general in the construction industry, just blindly signing contracts like that. What they're doing, they're basically signing away exposure and liability under a means and methods labor law 200 analysis in terms of signing signing on to the fact that they now have authority over the means and methods of the subcontractors work activities. I can't stress enough that I would tell those clients, don't do that. I also can't tell you how many times I've seen that type of boilerplate contract be signed and executed by the parties to the detriment of the city when in an exhibit or a rider or some form of, you know, corollary paperwork to the contract, the exact opposite thing is put forth and the GC, while they clearly intend not to have responsibility for the means and methods of the subcontractors work, they're also stuck with this provision in the boilerplate part of the contract and what the courts do with that. That's all that stuff is presented on motion practice. And typically a court will just throw up its hands and find issues of fact in that regard, thereby cutting off one of our major, you know, arguments for dismissal. So it's a little bit of a practice point. That's something I talk to some of my repeat clients about going forward and some listen, some don't. Um, but those are the basically those are basically the two major sub categories of claims under Labor law. 200. Now another caveat to this, is it another caveat to what I'm saying is this and this this has to do with the dangerous or defective condition prong of the statute when the condition that is alleged to have injured the worker arises from the work activities of the worker, um, him or herself or from his or her employer. It's not a it's not a defective premises condition. We frequently say we frequently see this where, let's say boiler installation work is being performed or some sort of mechanical work is being performed that generates oil or a lubricant that drips on the floor and a worker slips and falls. Um, if the slipping condition, in this case the oil is created by the work itself, um, typically that's not considered a dangerous or defective condition and a plaintiff would have to explore other means to to succeed on the claim that's deemed a means and methods case. And the other elements apply that I just reviewed. Okay. Another another major caveat to labor Law 201 that is very different than what we reviewed last week with labor Law 240 and one that actually, you know, here's the rare case. It benefits the defendants is that the injured workers comparative negligence or comparative fault is at play with labor law 200 and frequently. You know, we we can blame the injured worker for for either causing the accident either maybe creating the condition that resulted in the accident, not following instructions and thereby not performing the work in a safe manner or the way it should have been by using the wrong tools or equipment, misusing tools or equipment, the whole spectrum of things that that a worker can do that that that we can argue caused or contributed to the accident or at least can support our affirmative defense. And our counterargument that the worker has a lot of comparative fault which should reduce the damages to the extent we can prove that um that is a decent overview of labor law 240 And in fact, I think I went I'm sorry, of 200 and I think I went ahead on my slides. I did. This is the slide with the general supervisor authority. We covered that. So we've now we've now and I'm just my eye is always on the time we've covered labor law 240 and 200. We're now into labor law 241 six. This one is a little more similar to labor law 240 and that it's a strict liability or an absolute liability statute. Um, it it puts liability on an owner or general contractor and their agents, even if those entities are not involved at all with the work. Um, that leads to the injury. Now, labor law. I'm sorry, and I'll get to the slide. Labor law 241 six Generally speaking, um, it is a broad catchall statute which puts the onus on the owners and the general contractors to again provide safe work sites. So in that sense it's very similar to Labor law 200, but it actually gets into the specific details of very express and specific work situation, ones that are covered by a companion law called the New York State Industrial Code. So basically, if there's an accident at the site and the plaintiff wants to succeed on a claim for a violation of New York labor law 241 six against an owner or a GC. He's going to he or she is going to have to show that a specific site safety regulation in the New York State Industrial Code, Section 23 was violated. And that's in the slide I just put up and we'll get to the code in a section. The code is a piece of the New York law that has dozens and dozens and dozens of subsections which cover basically everything I can possibly think of at a construction site, everything from ladders and scaffolds to power tools to excavation equipment to. And I'll get into a funny anecdote in a second. Even offshore oil Derrick drilling operations think that's actually one of them. So what a plaintiff's lawyer will do what an injured workers injured workers lawyer will do is they'll bring the complaint. They'll play it. They'll plead violations of New York State labor law 240 Section 200. And they'll also plead a violation of Section 241 six. And then they will cite as a predicate. Let me get to the list. They will cite as a predicate one or 2 or 50 of the subject of the subsections. I'm scrolling through on my screen right now. And you'll see under all these sub part titles, you'll see different types of scenarios, different types of equipment, different types of tools. All of them have safety requirements and all of them have requirements that the law has promulgated for owners and GCS to be aware of. Now, again, how is the owner or GC responsible for ensuring that the work of the subcontractors is following these requirements? How are they, for example, making sure that the power tools used by the Carpenters have the correct guards on the saws? I'm talking about that level of detail. They can't. The reality is they can't, but they're stuck with strict liability or absolute liability under the harsh auspices or mandates of labor law. 241 six. It's harsh in that sense, just like with labor law 240. Now, in a practical as a practical note, what owners and GCS do faced with this scenario is they build in risk transfer provisions in the contracts they have with the subcontractors. And in that way they can transfer risk and share blame and move, move, fault and damages downstream. That is for another day. That has an entire class devoted to it. I'm here simply to talk about the actual requirements of the law and the case law that has interpreted it. So it basically what the plaintiffs lawyers will do, they'll include in the pleadings a list of the industrial code sections that we see here that they claim to have been violated. Lots or lots are pretty basic. You know, you have a fall from a ladder. Not only is there a claim brought under labor law 240, but they'll bring 241 six and they'll cite to the requirements that exist in some of these lists for ladder ladder safety. Same thing with scaffold safety. But there's a lot of there's a lot of areas that that workers get hurt that don't involve those types of things. They don't involve fall from heights. For example, I have a case, a common case when a worker is using a power saw and, you know, the appropriate guard is not on the saw or the guard is attached to the saw wrong or defective. And, you know, and the saw becomes caught in a piece of wood and the saw kicks up and badly cuts the worker's arm. You know that's not a label I-240 case. Gravity. Gravity's not involved. It's arguably a labor law 200 case under the means and methods analysis we just discussed. But it's also primarily going to be a labor law 241 six claim. And in that particular example, you know, the plaintiffs will cite my my cursor is on top of it. They'll cite industrial code, Industrial code, section 23, subsection 1.12, which is the guarding of power driven machinery. And as the defense lawyer, we have to go and actually look at that code section and and you know, first obviously learn about it and become familiar with it. But we have to determine whether or not it can apply to our accident. So in a broad sense, this entire list we see here of under under Section 23 of the industrial code or the or the specific site safety requirements for the individual things that we see here, the tools, the equipment, the environment, etcetera, now. There's a couple of couple of situations here. The courts of New York have said, well, you can't just do this willy nilly. We have to actually look at the industrial code provision and see if it will support your labor law 241 six claim. And they do that in one of in two ways. The first way is to see whether or not the provision is specific enough to impute liability under 241 six. Some of these provisions that we're looking at are general safety standards for things like, you know, general worksite housekeeping, general organization and maintenance of debris. They're not what the courts have deemed specific enough. In other words, they don't provide enough specific direction so that the owner or GC can discover the deficiency or the hazard and remedy it. So the first thing you got to look at is whether or not the code provision cited by the plaintiff's lawyer in the pleadings is specific enough to support the 241 six claim. If it's not specific enough, it's not going to support the claim and we might be able to get the claim dismissed on that ground. The second situation is whether or not the industrial code provision cited by the plaintiff's lawyers in the pleadings is factually applicable to what actually occurred to cause the accident. Now, if if someone slips on a banana peel at the site, you know, and the plaintiff's lawyer pleads, there was a violation of I think it's 23 1.21, which is ladders and ladders. That's a pretty obvious example. It's not going to be factually applicable to to the actual accident at the site. Now this gets a little comical sometimes because what lazy worker, lazy plaintiff's lawyers will do sometimes and I say lazy with the most affection I've seen lawyers. And I had one case in particular. I've seen lawyers copy and paste the entire industrial section 23 of the industrial code into the pleadings, into the bill of particulars. It's ridiculous. And as the defense lawyer, you just throw up your hands at that point and you say, well, there's dozens of them. How do any of these apply in the case? I'm thinking of a case I actually got dismissed a couple of years ago. A plumber was burned. They were doing a high rise construction of a residential condo building in Manhattan. And a plumber, an employee of the plumbing sub, was installing a fancy luxury sink in one of the bathrooms. And I think his coworkers, if I remember correctly, had failed to turn off the hot water to a valve that was not yet completed. And when he opened the valve scalded, his hands were scalded because hot boiling water rushed out and he suffered a burn injury on his hand. Pretty straightforward accident. We ended up getting it dismissed for various other reasons. But in the pleadings and this is the one I was this is the one I always think of the injured workers lawyer copied and pasted the entire industrial code section, and he even copied the stuff. Look where my cursor is. Subpart 23.8. He copied the ones involving mobile cranes, tower cranes and derricks. So the the lawyer who covered the deposition, rather than just focus in on the the relevant provision, he decided to have a little fun and demonstrate how ludicrous a lot of these claims were. So he went painstakingly. He went line by line code provision by code provision. And he he was asking questions such as did your accident involve offshore oil drilling? And you should have seen the look on the injured workers face because he didn't create the pleadings. He had no idea. And it was a ultimately it was a bit of fluff, but it was a fun demonstration in a sense of how ridiculous some of the pleadings can be. What the plaintiff's lawyer should be doing is narrowly focusing, focusing in on the specific provisions that arguably apply to their accident and which the courts have deemed to be sufficiently specific. And there's several in particular. Most of these, unless the accident is something that we rarely see, maybe someone does get hurt on an oil Derrick, I don't know. But the ones we normally see are trip and falls, falls from ladders, falls from scaffolds. Et cetera. Illumination Electric shock is another big one. I wanted to add to what you were saying in terms of when plaintiffs actually, you know, assert all of these in numerous industrial codes and we have to deal with them not only at deposition, but also when it comes time for summary judgment. We have to seek to dismiss all of them. As ridiculous as each one is, we can't just say it's just not applicable. So we actually have to go through each industrial code on a summary judgment motion. So if they do 30, we have to go through 30 and, you know, show why they're not applicable to the facts of this case and usually drum up some case law to support our position, even though at some point plaintiff will never assert those claims. And then in opposition to our motion, they'll just completely ignore provisions. And what also on the converse, what can happen is that sometimes plaintiffs realize when they get to summary judgment portions of their case that, oh, although I've asserted 10 or 15 industrial code provisions, I missed the actual industrial code provision that is applicable to my case. So at that time they can and the courts have held they're allowed to do this. And even though it's past note of issue and they've already served several bills of particulars setting forth what their allegations are, they can then, in their summary judgment motion, assert a new industrial code that they feel is applicable to the case. Even if we've gone to the point where we have an expert engineering witness that is going to go through, you know, going back to to 40, maybe explaining why 240 is inapplicable and then explaining why each industrial code isn't applicable. Now we have to deal with this new industrial code that plaintiff may have asserted at the time of summary judgment and that that always becomes a pain. So we you know, when we do initially assess and evaluate the case, even if plaintiff hasn't. A asserted an allegation of the correct industrial code that we think is applicable. We will put that into our analysis. And and even if it comes to having an engineer discuss that with them so that we are ready for if and when plaintiff actually does assert that allegation. Right, Dave? Yeah. And we see cutting, cutting through all the noise of some of the lazy approaches we do see. Some of them are very common when there's a tripping or a slipping accident at a site. Snow and ice, the oil well, not the oil, but, you know, tripping over a improperly positioned wire. Et cetera. Et cetera. The big one that is implicated is 23 31.7. My cursor is at it now. Protection from general hazards. There are subsections in each of these provisions that cover specific scenarios such as tripping and slipping hazards that I just described. There's also subsections for overhead hazards, things falling from above, drowning hazards. Another major one that we see, I referred to it earlier. 23 1.12. The guarding of power driven machinery. What we see a lot happening. Here's a here's something to be on on the look for. We see a lot of times workers who need to use a power tool in a in a tough spot to reach. So what they do is they can't get their grinder or their Sawzall into the spot because of the guard. It won't fit or it's awkward. They'll take the guard off and the next thing you know, they they lose control of the power tool. And due to the, you know, due to the absence of the guard, it could hurt them. They never admit to it. Of course, they'll always say that their foreman directed them to take it off. But, you know, that's that's definitely an avenue of defense to explore. One of the big ones we see these days currently trending is the frequent use of 23 1.13, which is electrical hazards. The common scenario for this is you have referred to it earlier. That's because it was in one of the leading cases. You have a worker on an A-frame or an extension ladder doing work in the ceiling. That worker comes into contact with an electrical current, perhaps from a improperly installed wire. Et cetera. And they'll fall from the ladder. And that triggers both labor Law 241 six under this provision and also labor law 240. And so the courts grapple with whether or not it's a 241 six case, a 240 case or perhaps both. And under under the current case law, it's hard to reach any real conclusion because the courts generally say issues of fact. Um, and you know, the cases are so factually specific. You know, they'll say an issue of fact as to whether it was the shock itself or the improperly placed ladder which resulted in the fall. Um, so that's a hotbed area where I would encourage any defense lawyers out there and the claims professionals to really take a look at some of the current case law, which I'd be happy to forward that to. The Court of Appeals in New York is dealing with on that issue. Um, you know, we we we do see a lot of overlap with labor law 240 and 241 six. The big difference in the two statutes when when there's a when there's a ladder or scaffold fall we see a lot of overlap. And the big difference, of course, is that with 240, there's no comparative fault on the part of the injured worker with 241 six, just like with 200, the worker's comparative fault is taken into account and can be really significant. Um, when when there's a accident that implicates both of those statutes, let's say the electrical shock leading to a fall from hazard leading to a fall from ladder, the plaintiff's lawyers always want to really pursue the 240 because that is the one where there'd be no comparative fault on their client and thus a reduction in the damages. But we do see a lot of overlap in terms of that have. Have an interesting case with with overlap. And it also brings up two interesting code sections that are very similar but that you know, have have little nuances to them which can change the facts of the case and the the outcome of a summary judgment or the trial. Um, and this is an overlap of a falling object case where you have a, you know, a potential 240 where an object might have fallen during demolition or, or just creation of some sort of space where the actual item that's fallen, it comes from a the work that the worker's actually performing. So there's, there's a new case. And I think I spoke about it last time when we were doing 240 where when a worker is in a in the position of doing demolition and that demolition falls on him, that 240 might not. Be applicable. But what may happen is usually what comes up is whether that whether that worker was wearing a hard hat, whether that worker was hit on the head. And two different code sections come into play here. One is 23, 1.7 A, which is overhead hazards and 23 .1. 8C1, which is head protection. Now, these two code provisions seem similar, so something falls on someone's head and there should have been protection from that item falling on their head. Now 1.7 A is interesting because it it does it recalls for overhead protection for areas normally exposed to falling materials and 1.8 C one regards to dangers for protection of the head where there's a danger of being struck by a falling object or materials. It doesn't seem very different. But it could be because what the question is, well, what is a what is an area that is normally exposed to falling objects as opposed to in the danger of being hit by a falling object? If you're working overhead and you're doing demolition, it might not be that there's you're in an area that has is normally exposed to falling objects. If you're just taking down certain things, however, you might be exposed to the danger of something falling because of the work that you're performing. And this could this could dictate whether one of these code provisions is applicable or both or neither. And that it becomes an interesting argument and interesting analysis when you're looking at that. And it just shows how code revisions are or can be, you know, confusing or fact specific. And I see that we are likely running up against our time. But the last, the last thought I have in terms of these individual code provisions is and I would say this as a warning to to the claims professionals and the defense lawyers, is that what we see a lot involves 23 1.30 illumination. We're seeing a lot of instances lately where the plaintiff's lawyers, the injured workers, lawyers are coaching their clients to include as a as a cause of the accident. During their deposition testimony. The alleged poor lighting of the of the area because the the lawyers know that by including that it will likely trigger the GC to have to implead or bring a third party action against the electrical subcontractor, thereby bringing in another insurance policy and perhaps an insurance carrier who would rather pay costs than than litigate. So really be on be on the lookout for that when analyzing a new claim, especially if you're insuring or representing an electrical sub. We have cases, we see that where the work is being performed outside at noon in broad daylight. So, you know, there's something going on there. So just just be aware of that. And just to go on top of that, and it's not as much anymore, but with with owner controlled insurance policies and policies, sometimes the electricians are outside of that policy. So for the for the contract general contractor and the insurance company that has it, the ownership, bringing in the mere allegation of illumination may trigger protection, may trigger coverage under that policy, at least for a defense by the by the electrical contractors policy. Thank you again for joining us today. I hope this session, in conjunction with last week's session, provided you with a general overview of 242 41 six and 200, and the three of us are available to answer any questions you have. If you want to pick our brain on something that comes across your desk, or if you have a question on any of these topics or anything in general, you can feel free to pick up the phone, call us, email us, you know where to find us.

Presenter(s)

DL
David LoRe
Partner
Milber Makris Plousadis & Seiden, LLP
MNJ
Michele Newsome, JD
Partner
Milber Makris Plousadis & Seiden, LLP
RM
Russell McBrearty
Partner
Milber Makris Plousadis & Seiden, LLP

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