New York Labor Law
Construction & Workplace Liability
Strict liability, real defenses, and how New York courts apply Labor Law §§ 200, 240, and 241.
This section covers New York Labor Law claims arising from construction and workplace accidents, with a focus on Labor Law §§ 200, 240(1), and 241(6). The analysis is written for claims adjusters, insurers, and defense counsel evaluating liability exposure, coverage implications, and litigation strategy in high-severity construction injury cases.
Recent Labor Law / Scaffold Law Decisions & Analysis
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APPELLATE DECISION
Labor Law § 240(1) Ladder Fall Defense: What Preserved a Factual Dispute in Gabriel
Read more: Labor Law § 240(1) Ladder Fall Defense: What Preserved a Factual Dispute in GabrielPractical guidance on ladder fall defense, early investigation, sole proximate cause, and summary judgment for New York claims professionals and litigators.
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APPELLATE DECISION
Tobon v Turner: Recalcitrant Worker Under § 240(1)
Read more: Tobon v Turner: Recalcitrant Worker Under § 240(1)The decision explains the critical difference between disobeying a safety rule and refusing to use an adequate, available safety device within the context of a Labor Law § 240(1) claim.
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APPELLATE DECISION
2026 New York Scaffold Law Trend: Courts Narrow the Gate
Read more: 2026 New York Scaffold Law Trend: Courts Narrow the GateNew York 2026 Scaffold Law cases show courts testing coverage before applying strict Labor Law § 240 liability.
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APPELLATE DECISION
Labor Law § 240 Rebar Mat Fall Defense | Marte v Tishman
Read more: Labor Law § 240 Rebar Mat Fall Defense | Marte v TishmanMarte shows how rebar mat fall claims can narrow Scaffold Law exposure while preserving Labor Law § 241(6) risk.
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APPELLATE DECISION
Runner v New York Stock Exchange, Inc. Applies to Recent Labor Law § 240(1) Hoisting Injury
Read more: Runner v New York Stock Exchange, Inc. Applies to Recent Labor Law § 240(1) Hoisting InjuryA First Department Labor Law § 240(1) decision applying Runner to a falling hoisted column and counterweight injury.
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APPELLATE DECISION
Unsecured Ladder Creates Labor Law § 240(1) Liability
Read more: Unsecured Ladder Creates Labor Law § 240(1) LiabilityAn unsecured ladder that shifts or moves for no apparent reason establishes a prima facie violation of Labor Law § 240(1).
Evergreen Guides & Defense Resources
Labor Law Defense Authority Library
Sole Proximate Cause Defense
When a worker’s conduct may be the only legal cause of an elevation-related accident under Labor Law § 240(1).
- Controlling Court of Appeals framework.
- Recent 2025–2026 Appellate Division decisions.
- Defense, investigation, and claims strategy.
Recalcitrant Worker Defense
When a worker’s refusal to use available protection may defeat liability.
Read the Guide → Labor Law § 240(1)Ladder Cases Defense Guide
Adequacy, placement, securing, misuse, and sole-proximate-cause principles.
Read the Guide → Labor Law § 240(1)Falling Objects Defense Guide
Securing requirements, elevation differentials, and the scope of the falling-object rule.
Read the Guide → Labor Law § 241(6)Industrial Code Defense Guide
Specificity, applicability, causation, and frequently litigated Industrial Code regulations.
Read the Guide → Labor Law § 200Means & Methods vs. Dangerous Condition
Control, supervision, actual notice, constructive notice, and selection of the correct liability theory.
Read the Guide → Labor Law §§ 240(1) & 241(6)Statutory Agent Liability Guide
Delegated authority to supervise or control the work may create statutory-agent liability.
Read the Guide →