Williams v RXR Construction & Development LLC
Attorneys and Parties
Brief Summary
Construction-site injury and risk-allocation dispute involving Labor Law § 240(1) [New York's Scaffold Law imposing liability for gravity-related elevation hazards], Labor Law § 241(6) [construction-site safety statute tied to violations of specific safety rules], and competing contractual and common-law indemnification claims among the owner, manager, contractor, subcontractors, and installer.
The motion court denied summary judgment dismissing plaintiff's Labor Law claims, denied several indemnity-dismissal motions, granted RXR parties summary judgment on contractual indemnification claims against United Glass Systems, granted United Glass Systems summary judgment on its contractual indemnification claim against National Wall Corp., dismissed all claims against Super G Construction Corporation, and later on reargument granted plaintiff summary judgment on Labor Law § 240(1) while continuing to deny dismissal of the claims against National Wall Corp. and denying United Glass Systems summary judgment on contractual indemnification against National Wall Corp.
The Appellate Division vacated the award of contractual indemnification in favor of the RXR parties against United Glass Systems, restored common-law claims against Super G Construction Corporation, granted National Wall Corp. dismissal of contractual indemnification claims by RXR SL Owner LLC and RXR Realty LLC, and granted RXR Construction & Development LLC dismissal of contractual indemnification, common-law indemnification, and contribution claims asserted against it by United Glass Systems, National Wall Corp., and Super G Construction Corporation.
Plaintiff was entitled to Labor Law § 240(1) relief because a 150-to-200-pound stack of 96-inch windows, leaning on edge and elevated a few inches off the ground, created the kind of gravity-related hazard covered by the statute. Super G Construction Corporation was not entitled to dismissal because testimony created a factual dispute over whether it helped unload, stack, and secure the windows. The indemnity rulings turned on contract text: RXR SL Owner LLC and RXR Realty LLC were not named indemnitees, RXR Construction & Development LLC could not obtain summary judgment without a negligence finding against United Glass Systems, and claims against RXR Construction & Development LLC failed where no contract or indemnity clause supported them.
Background
Plaintiff, a construction worker, was injured when an unsecured stack of windows in a storage room fell on him at a construction project. The windows were heavy, about 96 inches tall, leaned on their edges, and were raised about 3 to 12 inches off the ground. RXR Construction & Development LLC had a contract with United Glass Systems, and United Glass Systems had a contract with National Wall Corp. Super G Construction Corporation performed window-installation work but had no contract with the other parties. After the accident, the parties disputed who unloaded, stacked, and failed to secure the windows, and they also litigated who owed contractual or common-law indemnity to whom.
Lower Court Decision
In the December 2, 2024 order, the Supreme Court denied dismissal of plaintiff's Labor Law §§ 240(1) and 241(6) claims, denied several motions concerning indemnity claims, granted the RXR parties summary judgment on contractual indemnification against United Glass Systems, granted United Glass Systems summary judgment on contractual indemnification against National Wall Corp., and granted Super G Construction Corporation summary judgment dismissing all claims against it. In the March 31, 2025 order on reargument, the court granted plaintiff summary judgment on Labor Law § 240(1), held plaintiff's Labor Law § 241(6) claim academic, and adhered to its refusal to dismiss the claims against National Wall Corp. while denying United Glass Systems summary judgment on contractual indemnification against National Wall Corp.
Appellate Division Reversal
The Appellate Division affirmed the grant of plaintiff's Labor Law § 240(1) claim and treated the Labor Law § 241(6) claim as academic. It held that Super G Construction Corporation should not have been dismissed because conflicting testimony created triable issues over whether Super G helped unload, stack, and secure the windows; however, only common-law claims were restored against Super G because it had no contract with the other parties. The Court further held that RXR SL Owner LLC and RXR Realty LLC were not entitled to contractual indemnification from United Glass Systems because they were not named indemnitees in the relevant contracts, and that RXR Construction & Development LLC was not entitled to summary judgment on contractual indemnification against United Glass Systems because the clause required proof of United Glass Systems' negligence, which had not been established as a matter of law. It also agreed that United Glass Systems was not entitled to summary judgment on contractual indemnification against National Wall Corp. because factual issues remained over whether National Wall Corp. stacked the windows negligently and caused the accident. Finally, it dismissed the contractual indemnification claims by United Glass Systems, National Wall Corp., and Super G Construction Corporation against RXR Construction & Development LLC because no supporting contracts or indemnity provision existed, and those claims were unopposed.
Legal Significance
The decision reinforces that Labor Law § 240(1) can apply even where the object falls from only a slight elevation, so long as the object's weight, size, and positioning create a significant gravity-related hazard. It also underscores that contractual indemnification depends strictly on the wording of the contract: only named indemnitees may recover, and a negligence-triggered indemnity clause cannot be enforced on summary judgment without a determination of negligence. In addition, the case shows that lack of a contract defeats contractual indemnity, while factual disputes over who created the dangerous condition can preserve common-law indemnification and contribution claims.
Heavy materials leaning unsecured on a construction site can trigger Labor Law § 240(1) even when raised only inches off the floor, and indemnity rights will rise or fall on precise contract language and unresolved negligence facts.