common-law negligence claim (New York) · Go Syfert
← New York issues

common-law negligence claim in New York

80 New York opinions name it 6 courts 1989–2026 16 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (47)

CaseFollowedCited
Mendoza v. Highpoint Associates, IX, LLCgreen
nyappdiv · 2011 · cited in 3 New York opinions naming this issue, 2012–2012
2 sentences

2012Shopping Ctr., 27 NY2d 103 [1970].) In other words, a claim arising pursuant to the provision is “tantamount to a common-law negligence claim in a workplace context.” (Mendoza v Highpoint Assoc., IX, LLC, 83 AD3d 1, 9 [1st Dept 2011].) Unlike Labor Law §§ 240 and 241, section 200 does not exempt one- and two-family homeowners from its scope.

2012Shopping Ctr., 27 NY2d 103 [1970].) In other words, a claim arising pursuant to the provision is “tantamount to a common-law negligence claim in a workplace context.” (Mendoza v Highpoint Assoc., IX, LLC, 83 AD3d 1, 9 [1st Dept 2011].) Unlike Labor Law §§ 240 and 241, section 200 does not exempt one- and two-family homeowners from its scope.

33
Russin v. Louis N. Picciano & Songreen
ny · 1981 · cited in 3 New York opinions naming this issue, 2007–2012
2 sentences

2012To be held liable under the statute, which is the codification of the common-law negligence standard, an owner must have had the authority to control the activity bringing about the injury (Russin v Louis N. Picciano & Son, 54 NY2d 311, 317 [1981]), or actual or constructive notice of the hazardous condition (see Buckley v Columbia Grammar & Preparatory, 44 AD3d 263, 272-273 [1st Dept 2007], lv denied 10 NY3d 710 [2008]; Griffin v New York City Tr.

2012To be held liable under the statute, which is the codification of the common-law negligence standard, an owner must have had the authority to control the activity bringing about the injury (Russin v Louis N. Picciano & Son, 54 NY2d 311, 317 [1981]), or actual or constructive notice of the hazardous condition (see Buckley v Columbia Grammar & Preparatory, 44 AD3d 263, 272-273 [1st Dept 2007], lv denied 10 NY3d 710 [2008]; Griffin v New York City Tr.

33
Gordon v. American Museum of Natural Historygreen
ny · 1986 · cited in 3 New York opinions naming this issue, 2001–2024
2 sentences

2024“To constitute constructive notice, a defect must be visible and apparent and it must exist for a sufficient length of time prior to the accident to permit defendant's employees to discover and remedy it” (Gordon v American Museum of Natural History, 67 NY2d 836, 838 [1986] [citations omitted]).

2001We further find no evidence to support a common-law negligence claim based upon the allegation that there existed a dangerous condition of which the State should have had either actual or constructive notice (see, Gordon v American Museum of Natural History, 67 NY2d 836, 837 ; Wilson v Proctors Theater & Arts Ctr. & Theater, supra, at 828).

23
D'Amico v. Christiegreen
ny · 1987 · cited in 3 New York opinions naming this issue, 1989–2013
2 sentences

2013We agree with the Tavern, however, that the common-law negligence claim against it should have been dismissed as the accident occurred off its premises and the Tavern owed decedent no duty beyond that set forth in General Obligations Law § 11-101 (see D’Amico v Christie, 71 NY2d 76, 85 [1987]).

2013We agree with the Tavern, however, that the common-law negligence claim against it should have been dismissed as the accident occurred off its premises and the Tavern owed decedent no duty beyond that set forth in General Obligations Law § 11-101 (see D’Amico v Christie, 71 NY2d 76, 85 [1987]).

23
Ross v. Curtis-Palmer Hydro-Electric Co.green
ny · 1993 · cited in 2 New York opinions naming this issue, 2024–2024
2 sentences

2024Co. , 81 NY2d 494, 505-506 [1993]).

2024Co. , 81 NY2d 494, 505-506 [1993]).

22
Debellas v. Verrillgreen
nyappdiv · 2008 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013Here, the accident occurred when defendant’s dog collided with plaintiff, and defendant’s alleged negligence in calling the dog does not provide a basis to depart from the strict liability rule recognized by the Court of Appeals in Petrone, Bard and Collier {see Bloomer v Shauger, 94 AD3d 1273, 1274 [3d Dept 2012] [“Although . . . defendant’s conduct on the day in question indeed may have evidenced some negligence on her part . . . , the Court of Appeals has made its position clear . . . ; therefore, we are constrained to view this matter solely in the context of strict liability” (citations o

2013Here, the accident occurred when defendant’s dog collided with plaintiff, and defendant’s alleged negligence in calling the dog does not provide a basis to depart from the strict liability rule recognized by the Court of Appeals in Petrone, Bard and Collier {see Bloomer v Shauger, 94 AD3d 1273, 1274 [3d Dept 2012] [“Although . . . defendant’s conduct on the day in question indeed may have evidenced some negligence on her part . . . , the Court of Appeals has made its position clear . . . ; therefore, we are constrained to view this matter solely in the context of strict liability” (citations o

22
Curbelo v. Walkergreen
nyappdiv · 2011 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013Here, the accident occurred when defendant’s dog collided with plaintiff, and defendant’s alleged negligence in calling the dog does not provide a basis to depart from the strict liability rule recognized by the Court of Appeals in Petrone, Bard and Collier {see Bloomer v Shauger, 94 AD3d 1273, 1274 [3d Dept 2012] [“Although . . . defendant’s conduct on the day in question indeed may have evidenced some negligence on her part . . . , the Court of Appeals has made its position clear . . . ; therefore, we are constrained to view this matter solely in the context of strict liability” (citations o

2013Here, the accident occurred when defendant’s dog collided with plaintiff, and defendant’s alleged negligence in calling the dog does not provide a basis to depart from the strict liability rule recognized by the Court of Appeals in Petrone, Bard and Collier {see Bloomer v Shauger, 94 AD3d 1273, 1274 [3d Dept 2012] [“Although . . . defendant’s conduct on the day in question indeed may have evidenced some negligence on her part . . . , the Court of Appeals has made its position clear . . . ; therefore, we are constrained to view this matter solely in the context of strict liability” (citations o

22
Bloomer v. Shaugergreen
nyappdiv · 2012 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013Here, the accident occurred when defendant’s dog collided with plaintiff, and defendant’s alleged negligence in calling the dog does not provide a basis to depart from the strict liability rule recognized by the Court of Appeals in Petrone, Bard and Collier {see Bloomer v Shauger, 94 AD3d 1273, 1274 [3d Dept 2012] [“Although . . . defendant’s conduct on the day in question indeed may have evidenced some negligence on her part . . . , the Court of Appeals has made its position clear . . . ; therefore, we are constrained to view this matter solely in the context of strict liability” (citations o

2013Here, the accident occurred when defendant’s dog collided with plaintiff, and defendant’s alleged negligence in calling the dog does not provide a basis to depart from the strict liability rule recognized by the Court of Appeals in Petrone, Bard and Collier {see Bloomer v Shauger, 94 AD3d 1273, 1274 [3d Dept 2012] [“Although . . . defendant’s conduct on the day in question indeed may have evidenced some negligence on her part . . . , the Court of Appeals has made its position clear . . . ; therefore, we are constrained to view this matter solely in the context of strict liability” (citations o

22
Williams v. City of New Yorkgreen
ny · 2004 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013As plaintiff concedes, the “firefighter’s rule” bars his common-law negligence claim against the City of New York, his municipal employer (see General Obligations Law § 11-106; Williams v City of New York, 2 NY3d 352, 363 [2004]).

2013As plaintiff concedes, the “firefighter’s rule” bars his common-law negligence claim against the City of New York, his municipal employer (see General Obligations Law § 11-106; Williams v City of New York, 2 NY3d 352, 363 [2004]).

22
Buckley v. Columbia Grammar & Preparatorygreen
nyappdiv · 2007 · cited in 2 New York opinions naming this issue, 2012–2012
2 sentences

2012To be held liable under the statute, which is the codification of the common-law negligence standard, an owner must have had the authority to control the activity bringing about the injury (Russin v Louis N. Picciano & Son, 54 NY2d 311, 317 [1981]), or actual or constructive notice of the hazardous condition (see Buckley v Columbia Grammar & Preparatory, 44 AD3d 263, 272-273 [1st Dept 2007], lv denied 10 NY3d 710 [2008]; Griffin v New York City Tr.

2012To be held liable under the statute, which is the codification of the common-law negligence standard, an owner must have had the authority to control the activity bringing about the injury (Russin v Louis N. Picciano & Son, 54 NY2d 311, 317 [1981]), or actual or constructive notice of the hazardous condition (see Buckley v Columbia Grammar & Preparatory, 44 AD3d 263, 272-273 [1st Dept 2007], lv denied 10 NY3d 710 [2008]; Griffin v New York City Tr.

22
Bard v. Jahnkegreen
ny · 2006 · cited in 3 New York opinions naming this issue, 2011–2017
2 sentences

2017The Court of Appeals addressed this question in Bard v Jahnke ( 6 NY3d 592 [2006], supra), where a carpenter who was working on the defendant’s farm was attacked and injured by the defendant’s breeding bull.

2011We reject the plaintiffs argument that this Court should recognize a common-law negligence claim based on the defendant’s actions in allegedly releasing six dogs in a public place, in light of the clear constraints against recognizing such claims imposed by the Court of Appeals holdings in Petrone v Fernandez ( 12 NY3d 546 [2009]), Bard v Jahnke ( 6 NY3d 592 [2006]), and Collier v Zambito ( 1 NY3d 444 [2004]), as well as this Court’s recent precedents of Wright v Fiore ( 77 AD3d 821 [2010]) and Egan v Hom ( 74 AD3d 1133 [2010] ).

13
Karoon v. New York City Transit Authoritygreen
nyappdiv · 2001 · cited in 3 New York opinions naming this issue, 2007–2013
2 sentences

2013Auth. ( 286 AD2d 648 [1st Dept 2001]), the majority bases its reversal of the judgment entered solely on the premise that the trial court improperly allowed a New York City Transit Authority (NYCTA) investigator to testify as to his conclusions and opinions which were based on NYCTA’s operating criteria which exceeded the common-law negligence standard of care.

2013Auth. ( 286 AD2d 648 [1st Dept 2001]), the majority bases its reversal of the judgment entered solely on the premise that the trial court improperly allowed a New York City Transit Authority (NYCTA) investigator to testify as to his conclusions and opinions which were based on NYCTA’s operating criteria which exceeded the common-law negligence standard of care.

13
Petrone v. Fernandezgreen
ny · 2009 · cited in 2 New York opinions naming this issue, 2011–2015
2 sentences

2015This Court reversed in Petrone , invoking the Bard dissent’s description of the Bard rule as being “that the strict liability involved in Collier is the only kind of liability the owner of a domestic animal may face — that, in other words, there is no such thing as negligence liability where harm done by domestic animals is concerned” (Petrone v Fernandez, 12 NY3d 546, 550 [2009], quoting Bard, 6 NY3d at 601 [R.S.

2011We reject the plaintiffs argument that this Court should recognize a common-law negligence claim based on the defendant’s actions in allegedly releasing six dogs in a public place, in light of the clear constraints against recognizing such claims imposed by the Court of Appeals holdings in Petrone v Fernandez ( 12 NY3d 546 [2009]), Bard v Jahnke ( 6 NY3d 592 [2006]), and Collier v Zambito ( 1 NY3d 444 [2004]), as well as this Court’s recent precedents of Wright v Fiore ( 77 AD3d 821 [2010]) and Egan v Hom ( 74 AD3d 1133 [2010] ).

12
Giuffrida v. Citibank Corp.green
ny · 2003 · cited in 2 New York opinions naming this issue, 2004–2011
2 sentences

2011In any event, the argument is unavailing, since the standard of proof required to establish causation on the statutory claim is lower than that required on the common-law negligence claim (see Giuffrida v Citibank Corp., 100 NY2d 72 [2003]; Cerati v Berrios, 61 AD3d 915 [2009]).

2004In any event, appellant does not specifically challenge the sufficiency or weight of the evidence concerning the verdict on the common-law negligence claim, whose required proof is more stringent than that for a Code violation and supports any implicit finding of statutory violations by the jury (see Giuffrida v Citibank, 100 NY2d 72, 81 [2003]).

12
Capasso v. Kleen All of America, Inc.green
nyappdiv · 2007 · cited in 2 New York opinions naming this issue, 2011–2011
2 sentences

2011Defendant met its initial burden of establishing that it did not supervise or control plaintiff’s manner or method of work (cf. Capasso v Kleen All of Am., Inc., 43 AD3d 1346, 1348 ), and plaintiffs failed to raise a triable issue of fact with respect thereto (see generally Zuckerman v City of New York, 49 NY2d 557, 562 ).

2011Defendant met its initial burden of establishing that it did not supervise or control plaintiffs manner or method of work (cf. Capasso v Kleen All of Am., Inc., 43 AD3d 1346, 1348 [2007]), and plaintiffs failed to raise a triable issue of fact with respect thereto (see generally Zuckerman v City of New York, 49 NY2d 557, 562 [1980]).

12
Zuckerman v. City of New Yorkgreen
ny · 1980 · cited in 2 New York opinions naming this issue, 2011–2011
2 sentences

2011Defendant met its initial burden of establishing that it did not supervise or control plaintiff’s manner or method of work (cf. Capasso v Kleen All of Am., Inc., 43 AD3d 1346, 1348 ), and plaintiffs failed to raise a triable issue of fact with respect thereto (see generally Zuckerman v City of New York, 49 NY2d 557, 562 ).

2011Defendant met its initial burden of establishing that it did not supervise or control plaintiffs manner or method of work (cf. Capasso v Kleen All of Am., Inc., 43 AD3d 1346, 1348 [2007]), and plaintiffs failed to raise a triable issue of fact with respect thereto (see generally Zuckerman v City of New York, 49 NY2d 557, 562 [1980]).

12
Zanghi v. Niagara Frontier Transportation Commissiongreen
ny · 1995 · cited in 2 New York opinions naming this issue, 2000–2010
2 sentences

2010By contrast, a common-law negligence claim may proceed where an officer is injured in the line of duty merely because he or she happened to be present in a given location, but was not engaged in any specific duty that increased the risk of receiving that injury” ( 85 NY2d at 439-440 [emphasis added]).

2010By contrast, a common-law negligence claim may proceed where an officer is injured in the line of duty merely because he or she happened to be present in a given location, but was not engaged in any specific duty that increased the *197 risk of receiving that injury " ( 85 NY2d at 439-440 [emphasis added]).

12
Gilson v. Metropolitan Operagreen
ny · 2005 · cited in 1 New York opinions naming this issue, 2025–2025
11
Weisbrod-Moore v. Cayuga Countygreen
ny · 2025 · cited in 1 New York opinions naming this issue, 2025–2025
11
Early v. Hilton Hotels Corp.green
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2024–2024
11
Nazario v. 222 Broadway, LLCgreen
nyappdiv · 2016 · cited in 1 New York opinions naming this issue, 2024–2024
11
Sarmiento v. C & E Associatesgreen
nyappdiv · 2007 · cited in 1 New York opinions naming this issue, 2024–2024
11
Ridolfi v. Williamsgreen
nyappdiv · 2008 · cited in 1 New York opinions naming this issue, 2024–2024
11
O'Leary v. S&A Electrical Contracting Corp.green
nyappdiv · 2017 · cited in 1 New York opinions naming this issue, 2024–2024
11
Quiroz v. Wells Reit-222 East 41st Street, LLCgreen
nyappdiv · 2015 · cited in 1 New York opinions naming this issue, 2024–2024
11
Mullins v. Center Line Studios, Inc.green
nyappdiv · 2021 · cited in 1 New York opinions naming this issue, 2022–2022
11
De Rosa v. Slattery Contracting Co.green
nyappdiv · 1961 · cited in 1 New York opinions naming this issue, 2022–2022
11
Cuffy v. City of New Yorkgreen
ny · 1987 · cited in 1 New York opinions naming this issue, 2022–2022
11
Berger v. Dykstragreen
nyappdiv · 1994 · cited in 1 New York opinions naming this issue, 2018–2018
11
Decotes v. Merritt Meridian Corp.green
nyappdiv · 1997 · cited in 1 New York opinions naming this issue, 2018–2018
11
Rice v. City of Cortlandgreen
nyappdiv · 1999 · cited in 1 New York opinions naming this issue, 2018–2018
11
Hutchins v. Finch, Pruyn & Co.green
nyappdiv · 1999 · cited in 1 New York opinions naming this issue, 2018–2018
11
Cook v. Thompkinsgreen
nyappdiv · 2003 · cited in 1 New York opinions naming this issue, 2018–2018
11
Hyland v. Cobbgreen
ny · 1929 · cited in 1 New York opinions naming this issue, 2017–2017
11
Medina v. Sears, Roebuck & Co.green
nyappdiv · 2007 · cited in 1 New York opinions naming this issue, 2017–2017
11
Urbina v. 26 Court Street Associates, LLCgreen
nyappdiv · 2004 · cited in 1 New York opinions naming this issue, 2016–2016
11
Rizzuto v. L.A. Wenger Contracting Co.green
ny · 1998 · cited in 1 New York opinions naming this issue, 2012–2012
11
Ortega v. Pucciagreen
nyappdiv · 2008 · cited in 1 New York opinions naming this issue, 2012–2012
11
Hess v. Bernheimer & Schwartz Pilsener Brewing Co.green
ny · 1916 · cited in 1 New York opinions naming this issue, 2012–2012
11
Persichilli v. Triborough Bridge & Tunnel Authoritygreen
ny · 1965 · cited in 1 New York opinions naming this issue, 2012–2012
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (33)

CaseCitedYears
Alicea v. Medjugorje Realty, LLC green
nyappdiv · 2022
2 sentences

2024The indemnification provision in CH2M's contract with the Port Authority is triggered by claims [*2]"to the extent arising from the negligent or willful intentional acts or omissions of the [CH2M or its subcontractors] in the performance of services." The Port Authority and PATH maintain that under the Second Department's decision in Alicea v Medjugorje Realty, LLC ( 210 AD3d 835 [2d Dept 2022]), the motion court should not have dismissed their cross-claim for contractual indemnification.

2024The indemnification provision in CH2M's contract with the Port Authority is triggered by claims [*2]"to the extent arising from the negligent or willful intentional acts or omissions of the [CH2M or its subcontractors] in the performance of services." The Port Authority and PATH maintain that under the Second Department's decision in Alicea v Medjugorje Realty, LLC ( 210 AD3d 835 [2d Dept 2022]), the motion court should not have dismissed their cross-claim for contractual indemnification.

22024–2024
Hechter v. New York Life Insurance green
ny · 1978
2 sentences

2024Hechter held only that "a cause of action against a bank for collecting an instrument over a forged indorsement is not time-barred if it is styled in contract and commenced within six years of accrual." ( Id. at 39-40 .) The Hechter Court explained that New York's adoption of the UCC was not intended impliedly to abrogate the existing common-law contract cause of action with respect to forged indorsements of negotiable instruments, and that cause of action's corresponding six-year limitations period. ( Id. at 38-39 .) Hechter did not, however, have occasion to address whether a common-law negl

2024Hechter held only that "a cause of action against a bank for collecting an instrument over a forged indorsement is not time-barred if it is styled in contract and commenced within six years of accrual." ( Id. at 39-40 .) The Hechter Court explained that New York's adoption of the UCC was not intended impliedly to abrogate the existing common-law contract cause of action with respect to forged indorsements of negotiable instruments, and that cause of action's corresponding six-year limitations period. ( Id. at 38-39 .) Hechter did not, however, have occasion to address whether a common-law negl

22024–2024
Scavetta v. Wechsler green
nyappdiv · 2017
2 sentences

2023Liability in this case is examined under the vicious propensity rule ( Scavetta v Wechsler , 149 AD3d 202 [1st Dept 2017]).

2023Liability in this case is examined under the vicious propensity rule ( Scavetta v Wechsler , 149 AD3d 202 [1st Dept 2017]).

22023–2023
In re Barron neutral
ny · 2002
2 sentences

2013Contrary to the tavern’s contention, the assault, if intentional, did not serve to sever potential liability under either the Dram Shop Act (see Catania v 124 In-To-Go, Corp., 287 AD2d 476 [2d Dept 2001], lv dismissed 97 NY2d 699 [2002]), or under a common-law negligence claim (see Wilder, 254 AD2d at 819 ; Panzera, 253 AD2d at 865 ).

2013Contrary to the tavern’s contention, the assault, if intentional, did not serve to sever potential liability under either the Dram Shop Act (see Catania v 124 In-To-Go, Corp., 287 AD2d 476 [2d Dept 2001], lv dismissed 97 NY2d 699 [2002]), or under a common-law negligence claim (see Wilder, 254 AD2d at 819 ; Panzera, 253 AD2d at 865 ).

22013–2013
Panzera v. Johnny's II green
nyappdiv · 1998
2 sentences

2013Contrary to the tavern’s contention, the assault, if intentional, did not serve to sever potential liability under either the Dram Shop Act (see Catania v 124 In-To-Go, Corp., 287 AD2d 476 [2d Dept 2001], lv dismissed 97 NY2d 699 [2002]), or under a common-law negligence claim (see Wilder, 254 AD2d at 819 ; Panzera, 253 AD2d at 865 ).

2013Contrary to the tavern’s contention, the assault, if intentional, did not serve to sever potential liability under either the Dram Shop Act (see Catania v 124 In-To-Go, Corp., 287 AD2d 476 [2d Dept 2001], lv dismissed 97 NY2d 699 [2002]), or under a common-law negligence claim (see Wilder, 254 AD2d at 819 ; Panzera, 253 AD2d at 865 ).

22013–2013
Wilder v. Nickbert Inc. green
nyappdiv · 1998
2 sentences

2013Contrary to the tavern’s contention, the assault, if intentional, did not serve to sever potential liability under either the Dram Shop Act (see Catania v 124 In-To-Go, Corp., 287 AD2d 476 [2d Dept 2001], lv dismissed 97 NY2d 699 [2002]), or under a common-law negligence claim (see Wilder, 254 AD2d at 819 ; Panzera, 253 AD2d at 865 ).

2013Contrary to the tavern’s contention, the assault, if intentional, did not serve to sever potential liability under either the Dram Shop Act (see Catania v 124 In-To-Go, Corp., 287 AD2d 476 [2d Dept 2001], lv dismissed 97 NY2d 699 [2002]), or under a common-law negligence claim (see Wilder, 254 AD2d at 819 ; Panzera, 253 AD2d at 865 ).

22013–2013
Hastings v. Sauve green
ny · 2013
2 sentences

2013Although plaintiffs contended at oral argument that the Court of Appeals’ recent decision in Hastings v Sauve (supra) — decided on May 2, 2013, just weeks before oral argument — permits a common-law negligence claim in this case, we need not reach that issue in light of our decision herein. .

2013Although plaintiffs contended at oral argument that the Court of Appeals’ recent decision in Hastings v Sauve (supra) — decided on May 2, 2013, just weeks before oral argument — permits a common-law negligence claim in this case, we need not reach that issue in light of our decision herein. .

22013–2013
Catania v. 124 In-To-Go, Corp. green
nyappdiv · 2001
2 sentences

2013Contrary to the tavern’s contention, the assault, if intentional, did not serve to sever potential liability under either the Dram Shop Act (see Catania v 124 In-To-Go, Corp., 287 AD2d 476 [2d Dept 2001], lv dismissed 97 NY2d 699 [2002]), or under a common-law negligence claim (see Wilder, 254 AD2d at 819 ; Panzera, 253 AD2d at 865 ).

2013Contrary to the tavern’s contention, the assault, if intentional, did not serve to sever potential liability under either the Dram Shop Act (see Catania v 124 In-To-Go, Corp., 287 AD2d 476 [2d Dept 2001], lv dismissed 97 NY2d 699 [2002]), or under a common-law negligence claim (see Wilder, 254 AD2d at 819 ; Panzera, 253 AD2d at 865 ).

22013–2013
Crosland v. New York City Transit Authority green
ny · 1986
2 sentences

2013Crosland involved the application of a specific rule, “rule 85,” which imposed a duty higher than that actually owed in the exercise of ordinary care (Crosland, 68 NY2d at 168-169 ).

2013Crosland involved the application of a specific rule, “rule 85,” which imposed a duty higher than that actually owed in the exercise of ordinary care (Crosland, 68 NY2d at 168-169 ).

22013–2013
Rusin v. Jackson Heights Shopping Center, Inc. green
ny · 1970
2 sentences

2012Shopping Ctr., 27 NY2d 103 [1970].) In other words, a claim arising pursuant to the provision is “tantamount to a common-law negligence claim in a workplace context.” (Mendoza v Highpoint Assoc., IX, LLC, 83 AD3d 1, 9 [1st Dept 2011].) Unlike Labor Law §§ 240 and 241, section 200 does not exempt one- and two-family homeowners from its scope.

2012Shopping Ctr., 27 NY2d 103 [1970].) In other words, a claim arising pursuant to the provision is “tantamount to a common-law negligence claim in a workplace context.” (Mendoza v Highpoint Assoc., IX, LLC, 83 AD3d 1, 9 [1st Dept 2011].) Unlike Labor Law §§ 240 and 241, section 200 does not exempt one- and two-family homeowners from its scope.

22012–2012
Griffin v. New York City Transit Authority green
nyappdiv · 2005
2 sentences

2012Auth., 16 AD3d 202 [1st Dept 2005]).

2012Auth., 16 AD3d 202 [1st Dept 2005]).

22012–2012
Ryder v. Mount Loretto Nursing Home, Inc. green
nyappdiv · 2002
2 sentences

2005“There are issues of fact whether [their] excavation . . . created an unreasonable risk of harm to plaintiff and was a proximate cause of plaintiffs injuries” (Davis, 299 AD2d at 929 ; see Marano v Commander Elec., Inc., 12 AD3d 571, 572-573 [2004]; Ryder, 290 AD2d at 894 ).

2002There are issues of fact whether Fennell’s excavation of the hole created an unreasonable risk of harm to plaintiff and was a proximate cause of plaintiffs injuries (see Ryder, 290 AD2d at 894 ).

22002–2005
Jock v. Fien green
ny · 1992
1 sentence

2026Labor Law § 200 codifies the common-law negligence standard ( see Samperi v City Safety Compliance Corp. , 225 AD3d at 724), while Labor Law §§ 240(1) and 241(6) "subject contractors and owners to absolute strict liability" ( Jock v Fien , 80 NY2d 965, 968 ).

12026–2026
Justin Nazario v. 222 Broadway, LLC, 222 Broadway, LLC v. Knight Electrical Services Corp. green
ny · 2016
12024–2024
De Rosa v. SLATTERY CONTRACTING CO., INC. neutral
ny · 1962
12022–2022
Berger v. Dykstra green
ny · 1994
12018–2018
Marshall v. Glenman Industrial & Commercial Contractor Corp. neutral
nyappdiv · 2014
12018–2018
DaSilva v. Haks Engineers, Architects & Land Surveyors green
nyappdiv · 2015
12018–2018
King v. New York City Transit Authority neutral
nyappdiv · 1999
12017–2017
Richardson v. Campanelli neutral
nyappdiv · 2002
12017–2017
Fanning v. Rockefeller University green
nyappdiv · 2013
12016–2016
Petrone v. Fernandez green
nyappdiv · 2008
12015–2015
In re Schutzman green
nyappdiv · 2003
12015–2015
Carafano v. metrosplash.com, Inc. green
ca9 · 2003
12013–2013
cluster 782479 green
ca9 · 2003
12013–2013
O'Connor-Miele v. Barhite & Holzinger, Inc. green
nyappdiv · 1996
12012–2012
Lusenskas v. Axelrod green
ny · 1993
12011–2011
Chiara v. Town of New Castle green
nyappdiv · 2009
12011–2011
Smith v. Sherwood neutral
nyappdiv · 2009
12011–2011
Egan v. Hom green
nyappdiv · 2010
12011–2011
Wright v. Fiore neutral
nyappdiv · 2010
12011–2011
Leon v. Martinez green
ny · 1994
12011–2011
Collier v. Zambito green
ny · 2004
12011–2011

Statutes the citing opinions construe

NY § N.Y. Labor Law § 200 (27) NY § N.Y. Labor Law § 240 (24) NY § N.Y. Labor Law § 241 (21) NY § N.Y. Alcoholic Beverage Control Law § 65 (6) NY § N.Y. General Obligations Law § 11-101 (5) NY § N.Y. General Obligations Law § 11-106 (4) NY § N.Y. General Obligations Law § 5-322.1 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 80 (1989–2026) OR 43 (1985–2025) TX 25 (1994–2026) WI 13 (1992–2026) IL 13 (1996–2026) OH 9 (1988–2020) CT 8 (1995–2025) AZ 5 (2012–2025) KY 5 (2014–2025) MN 5 (1980–2026) MI 4 (1988–2020) NM 4 (1989–2016) WA 3 (1978–2008) DE 2 (2024–2024) TN 2 (2001–2002) GA 2 (2013–2020) NC 2 (2022–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check