Dahar v. Holland Ladder & Manufacturing Co.

Summary

The New York Court of Appeals held that a factory employee injured while cleaning a manufactured steel wall module was not engaged in an activity protected by Labor Law § 240 (1). The court declined to extend the statute's protections to cleaning a product during a manufacturing process and affirmed dismissal of the plaintiff's claim.

Holdings

1. A factory employee cleaning a manufactured product in the course of a manufacturing process is not engaged in an activity protected by Labor Law § 240(1).
2. The court did not reach whether Bechtel and the Martins were contractors or owners because Dahar's activity was outside the statute's protected scope.

Questions Presented

1. Whether cleaning a manufactured steel wall module during a manufacturing process constitutes protected activity under Labor Law § 240(1).
2. Whether the defendants could be liable as contractors or owners under Labor Law § 240(1) based on the accident.

Disposition

affirmed