Saint v. Syracuse Supply Co., 25 N.Y.3d 120 (2015)

Under New York Labor Law § 240(1), work that involves a significant physical change to the configuration or composition of a structure, such as installing extensions to a billboard frame to accommodate a new advertisement, constitutes an alteration, triggering the statute’s protections.

Summary

Joseph Saint, an employee injured while installing extensions to a billboard, sued the property owner, alleging violations of New York Labor Law §§ 240(1), 240(2), and 241(6). The Court of Appeals reversed the Appellate Division’s decision, holding that Saint’s work constituted an alteration under Labor Law § 240(1) because he was changing the billboard’s structure. The court emphasized that the installation of extensions to the billboard frame, requiring the removal of the existing advertisement and the application of new vinyl, was more than cosmetic modification, it involved a significant physical change. The Court also found violations of § 240(2) and § 241(6) due to the lack of safety rails and because the work was deemed construction, which included alteration.

Facts

Joseph Saint, a construction worker, was part of a crew tasked with replacing a billboard advertisement. The billboard was elevated, consisting of a metal frame with panels. The new advertisement required plywood extensions to be attached to the frame. Saint was injured when he fell from a catwalk while helping to move the old vinyl advertisement over the frame. At the time of the accident, the extensions had already been constructed and were to be attached to the billboard frame, and the crew was removing the old advertisement in preparation for the installation of the extensions.

Procedural History

Saint sued the property owner, Syracuse Supply Company, alleging violations of Labor Law §§ 240(1), (2), and 241(6). The Supreme Court denied both parties’ motions for summary judgment, finding issues of fact. The Appellate Division reversed, granting summary judgment to the defendant. The Court of Appeals then granted leave to appeal, and reversed the Appellate Division, reinstating Saint’s claims.

Issue(s)

1. Whether Saint’s work, involving the installation of extensions to a billboard frame to accommodate a new advertisement, constituted an