Brown v. Christopher Street Owners Corp., 78 N.Y.2d 782 (1991)

Labor Law § 240(1), which imposes absolute liability for failing to provide safety devices during building cleaning, does not extend to routine household window washing by an individual hired by an apartment owner.

Summary

Arthur Brown, a window washer, was injured when he fell from the second-floor ledge of a cooperative apartment building while washing windows for Anne Hack. He sued the building owner under Labor Law § 240(1), which provides absolute liability for failing to furnish appropriate safety devices during building cleaning. The New York Court of Appeals held that § 240(1) does not apply to routine household window washing. The court distinguished this from large-scale commercial cleaning or other enumerated activities like painting, concluding that the legislature did not intend to impose such broad liability for ordinary household tasks.

Facts

Arthur Brown was hired by Anne Hack to wash the windows of her one-bedroom cooperative apartment in Manhattan.
While attempting to wash the exterior of a window from a second-floor ledge, Brown fell and sustained injuries.
Brown subsequently brought a claim against the building owners, Christopher Street Owners Corp., alleging violations of Labor Law § 240(1).

Procedural History

The lower courts’ decisions were not explicitly stated in the Court of Appeals decision. The Court of Appeals affirmed the order of the Appellate Division, implying the lower courts found against the plaintiff, Brown. The Court of Appeals’ decision represents the final determination in this case.

Issue(s)

1. Whether Labor Law § 240(1) applies to routine window washing of a single apartment in a cooperative building.
2. Whether Labor Law § 202 provides the exclusive Labor Law remedy in cases involving window cleaning.

Holding

1. No, because the “cleaning” encompassed under Labor Law § 240 (1) does not include routine, household window washing.
2. The court did not reach this issue.

Court’s Reasoning

The court reasoned that Labor Law § 240(1) was not intended to cover routine household tasks. The court distinguished this situation from other scenarios where § 240(1) would apply, such as the painting of a house (Rivers v. Sauter) or the cleaning of all the windows of a large, nonresidential structure (Koenig v. Patrick Constr. Corp.). The court stated that “the routine cleaning of the five windows of a single cooperative apartment by an individual engaged by the apartment owner is not the kind of undertaking for which the Legislature sought to impose liability under Labor Law § 240.” The court emphasized the distinction between large-scale commercial endeavors and small-scale residential tasks. The court explicitly declined to address whether Labor Law § 202 provides the exclusive remedy because the parties did not raise the issue in their briefs, citing Terry v Young Men’s Hebrew Assn., 78 NY2d 978, 979. This highlights the importance of proper legal briefing and issue presentation to the court. The ruling reinforces the principle that statutes should be interpreted in light of their intended purpose and scope, avoiding interpretations that would lead to absurd or unintended results. This case serves as a limiting principle on the broad application of Labor Law § 240(1), ensuring it is applied to construction-related activities rather than ordinary household maintenance.