13 N.Y.3d 592 (2009)
The homeowner’s exemption to Labor Law §§ 240 and 241 applies when homeowners’ involvement is limited to discussing desired results, not dictating the method or manner of the work performed.
Summary
This case addresses the scope of the homeowner’s exemption under New York Labor Law §§ 240 and 241. The plaintiff, a contractor, was injured while performing renovations on the defendants’ two-family home. The Court of Appeals held that the defendants were entitled to the homeowner’s exemption because their involvement was limited to aesthetic decisions and general supervision, not direct control over the method and manner of the work. The court reasoned that the defendants did not provide equipment or work materials and were not present when the plaintiff was injured. This case clarifies that simply expressing preferences about the outcome of the work does not negate the homeowner’s exemption.
Facts
The defendants hired the plaintiff, who was also their neighbor, to renovate an apartment in their two-family home. The plaintiff’s work included installing appliances. The plaintiff fell from a ladder while installing a vent on the roof and sustained injuries. The defendants instructed the plaintiff to place the vent through the roof.
Procedural History
The plaintiff sued the defendants, alleging violations of Labor Law §§ 200, 240(1), and 241(6), and common-law negligence. The Supreme Court denied both the defendants’ motion for summary judgment (based on the homeowner’s exemption) and the plaintiff’s cross-motion for summary judgment. The Appellate Division reversed, granting the defendants’ motion for summary judgment and dismissing the complaint. The plaintiff appealed to the Court of Appeals.
Issue(s)
Whether the defendants exercised sufficient direction and control over the plaintiff’s work to overcome the one- or two-family dwelling exemption found in Labor Law §§ 240 and 241, thereby making them liable for the plaintiff’s injuries.
Holding
No, because the defendants’ participation was limited to discussing the desired results and making aesthetic decisions, rather than directing or controlling the manner and method of the work.
Court’s Reasoning
The Court of Appeals affirmed the Appellate Division’s decision, holding that the defendants were entitled to the homeowner’s exemption. The court emphasized that the exemption was enacted to reflect the practical realities of the relationship between homeowners and contractors. The court distinguished between discussing desired outcomes and directing the *manner* in which the work is performed. Here, the defendants’ direction to the plaintiff to place a vent through the roof was an aesthetic decision and did not constitute the type of direction and control that would negate the homeowner’s exemption. The court quoted Duda v. Rouse Constr. Corp., stating that whether a defendant’s conduct amounts to direction and control depends upon the degree of supervision exercised over “the manner and method of the work to be performed.” The court also noted that the defendants did not provide the plaintiff with equipment or materials and were not present when the injury occurred. The court also held that the Labor Law § 200 and common-law negligence claims failed because the defendants did not exercise supervisory control over the activity that caused the injury.