Joyce v. Rumsey Realty Corp., 17 N.Y.2d 118 (1966)
A contractor’s violation of the New York Labor Law, specifically the requirement to complete flooring as a building progresses, constitutes conclusive evidence of negligence and imposes absolute liability when a worker is injured as a result of that violation.
Summary
The plaintiff, a construction worker, was injured when a plank he was standing on broke, causing him to fall through an uncovered opening to the basement. The defendant, the contractor, had failed to comply with New York Labor Law requiring flooring to be completed as the building progressed. The Court of Appeals held that the contractor’s violation of the Labor Law constituted conclusive evidence of negligence, and the plaintiff was entitled to a directed verdict on the issue of liability. The court reasoned that the statute imposes an absolute and unconditional duty on the contractor, and the worker’s injury directly resulted from the contractor’s failure to fulfill that duty. The fact that the plank broke was considered a concurrent cause, not negating the contractor’s primary liability.
Facts
The plaintiff was working on the fourth floor of a building under construction. The first, second, and third floors had not been fully floored as required by the New York Labor Law. The plaintiff was moving planks when the plank he was standing on broke. As a result, the plaintiff fell through the open floors into the basement, sustaining injuries.
Procedural History
The trial court directed a verdict for the plaintiff against the defendant Bumsey, the contractor, on the issue of liability, leaving the determination of damages to the jury. The contractor appealed this decision, arguing that the breaking of the plank was an intervening cause that should negate their liability. The Court of Appeals affirmed the trial court’s decision, holding that the contractor’s violation of the Labor Law constituted conclusive evidence of negligence.
Issue(s)
Whether a contractor’s failure to comply with the New York Labor Law requiring flooring to be completed as a building progresses constitutes conclusive evidence of negligence when a worker is injured as a result of falling through an uncovered opening, warranting a directed verdict on the issue of liability.
Holding
Yes, because the statute imposes an absolute and unconditional duty on the contractor to complete flooring, and the worker’s injury directly resulted from the contractor’s failure to fulfill that duty. The violation of the statute is conclusive evidence of negligence, regardless of other contributing factors.
Court’s Reasoning
The Court of Appeals emphasized that the New York Labor Law imposes a “flat and unvarying” duty on contractors to complete flooring as a building progresses. Citing prior cases like Koenig v. Patrick Constr. Corp., the court reiterated that “For breach of that duty, thus absolutely imposed, the wrongdoer is rendered liable without regard to his care or lack of it.” The court further stated that a violation of such a statute is “conclusive evidence of negligence,” warranting a directed verdict. The court rejected the argument that the breaking of the plank was an intervening cause, stating that “Something must project him into the hole but that something cannot be more than a concurrent cause of the injury.” The court feared that allowing a jury to find no cause of action would nullify the statute’s protective intent for workers in situations such as the plaintiff’s. The court concluded that the statute places absolute and unconditional liability on the contractor in favor of the workman who falls through the floor opening that the statute insists must be covered.