Matt represented a subcontractor performing renovation work in the basement of a New York City building. The plaintiff alleged that several laminated metal sheets, stored upright against a wall, toppled over and pinned him to the floor while he was working. Relying on Labor Law § 240(1), the plaintiff sought to impose strict, nondelegable liability based on the theory that the materials should have been secured.

On appeal, the Appellate Division adopted Matt’s argument that the Scaffold Law did not apply to the accident. The Court held that the evidence established the laminated sheets were not required to be secured for purposes of the plaintiff’s work, and that the accident did not arise from an elevation-related hazard contemplated by § 240(1). As a result, the plaintiff’s attempt to impose absolute liability was rejected.

Practical Impact for Claims Adjusters, Insurers, and Defense Counsel

This decision provides critical guidance for evaluating and defending Labor Law § 240(1) claims involving falling objects:

• Limits Scaffold Law exposure by reinforcing that not every falling object triggers § 240(1); the object must be one that required securing for the task being performed;
• Supports early claim triage and motion practice, helping carriers distinguish between true elevation risks and ordinary workplace accidents;
• Helps insurers and defense counsel avoid automatic reserve inflation driven by improper Scaffold Law allegations;
• Strengthens defenses for subcontractors and downstream insureds in renovation and interior construction projects; and
• Provides appellate authority to push back on overbroad § 240(1) theories commonly asserted in NYC construction cases.

This case is a strong example of how focused appellate advocacy can eliminate strict liability exposure, preserve common-law defenses, and materially reduce risk in high-severity Labor Law claims.