91 N.Y.2d 783 (1998)

New York Labor Law § 240(1) applies to elevation-related risks where a worker or object falls from a height, not to situations where an object on the same level is propelled horizontally due to the failure of a hoisting or securing device.

Summary

Plaintiff, while dismantling a coal conveyor system in an underground vault, was injured when a cable, used to hoist equipment, snapped, causing a 200-pound tension ball to strike him. The Court of Appeals reversed the Appellate Division’s order, holding that the injury did not result from an elevation-related hazard within the meaning of Labor Law § 240(1). The court emphasized that the statute protects against risks stemming from elevation differentials, not from the horizontal propulsion of an object on the same level.

Facts

Plaintiff was dismantling a coal conveyor system in a subterranean concrete vault. Dismantled machinery was lifted out of the vault by a crane at ground level, its cable lowered through an opening. A 200-pound metal tension ball was attached to the cable, used to drag dismantled machinery across the vault floor for hoisting. Equipment snagged on the uneven vault floor. Unaware, the crane operator continued to exert tension. The cable snapped, propelling the tension ball against the plaintiff, causing injury.

Procedural History

The Supreme Court granted the defendant’s cross-motion for partial summary judgment, dismissing the plaintiff’s Labor Law § 240(1) cause of action. The Appellate Division modified the Supreme Court’s order, reversing the dismissal of the § 240(1) claim, concluding the work exposed the plaintiff to risks associated with elevation differentials. The Court of Appeals reversed the Appellate Division’s order.

Issue(s)

Whether the plaintiff’s injury, caused by a horizontally propelled object due to a snapped cable during dismantling work, constitutes an elevation-related hazard covered under New York Labor Law § 240(1)?

Holding

No, because the injury did not result from an elevation-related hazard as contemplated by Labor Law § 240(1). The statute applies to risks associated with falling from a height or being struck by a falling object, not to situations where an object on the same level is propelled horizontally.

Court’s Reasoning

The Court of Appeals reasoned that Labor Law § 240(1) is designed to protect workers from elevation-related hazards, specifically risks arising from work performed at heights or involving the falling of persons or objects. The court distinguished the case from situations where a worker falls from a height or is struck by a falling object due to inadequate safety devices. Here, the plaintiff’s injury was caused by the horizontal propulsion of the tension ball, which was not a consequence of an elevation differential. The court cited Rocovich v Consolidated Edison Co. (78 NY2d 509) and Ross v Curtis-Palmer Hydro-Elec. Co. (81 NY2d 494) to reinforce the principle that § 240(1) applies to situations where the elevation differential itself poses a risk. The court focused on the mechanism of injury, noting it did not involve a gravity-related event where the worker or the object fell a significant distance. The decision emphasizes a narrow interpretation of § 240(1), limiting its application to scenarios where gravity-induced risks are directly implicated.