A New York appellate court ruled on August 5, 2026, in the case of Palma v. Cheer Hall, LLC, affecting personal injury claims for construction workers. The decision primarily impacts workers who may be injured on residential properties and the property owners who hire them. The court's ruling clarifies the legal exemptions that protect certain property owners from liability under New York's Labor Law.
The case arose when Jose Figueroa Palma, the injured plaintiff, and his wife filed a lawsuit after Palma sustained injuries while working on a property owned by Cheer Hall, LLC. The couple sought damages for personal injuries, claiming that the property owner violated specific sections of the Labor Law designed to protect workers. These sections, known as Labor Law §§ 240(1) and 241(6), impose strict safety requirements on property owners.
Palma's injuries occurred on November 20, 2020, while he was performing work on the Rockland County property owned by Cheer Hall. The plaintiffs alleged that the property owner failed to provide adequate safety measures as required by the Labor Law. In response, Cheer Hall filed a motion for summary judgment, arguing that it was exempt from liability under the Labor Law because it owned a one- or two-family dwelling.
The case reached the Appellate Division of the Supreme Court of the State of New York after the Supreme Court, Rockland County, issued an amended order on October 27, 2023. This order granted Cheer Hall's motion to dismiss the Labor Law claims and denied the plaintiffs' request for summary judgment on the issue of liability. The plaintiffs then appealed the decision.
The court ruled that Cheer Hall was exempt from liability under Labor Law §§ 240(1) and 241(6) because the property was classified as a one- or two-family dwelling. The court stated, "The homeowner exemption is applicable when an owner of a one- or two-family dwelling contracts for work that directly relates to the residential use of the home, even if the work also serves a commercial purpose." This ruling emphasized that property owners can be exempt if they do not control the work being performed.
The judges involved in the ruling included Betsy Barros, Valerie Brathwaite Nelson, Barry E. Warhit, and Elena Goldberg Velazquez. Their decision affirmed the lower court's ruling, stating that the plaintiffs did not raise a triable issue of fact to counter the defendant's claims.
This ruling has significant implications for both construction workers and property owners. It clarifies the circumstances under which property owners can be held liable for injuries sustained by workers on their premises. The court's decision reinforces the homeowner exemption, which protects owners of one- or two-family dwellings from liability if they do not direct or control the work being done.
Going forward, this ruling may impact how personal injury claims are handled in similar cases. Workers injured while performing tasks on residential properties may find it more challenging to pursue claims against property owners if those owners can demonstrate that they meet the criteria for the homeowner exemption.
Additionally, the ruling may encourage property owners to be more cautious in hiring contractors and ensure that they do not exert control over the work being performed. This could lead to a shift in how construction projects are managed on residential properties, as owners may seek to limit their liability by adhering to the guidelines established in this case.
Details were not available in the court filing regarding whether the plaintiffs plan to appeal this decision further. There is no indication of any related cases pending at this time.