Syracuse Personal Injury Law Blog
When workplace safety measures intersect with federal regulatory frameworks, determining liability can become challenging for courts. A recent New York case demonstrated how courts evaluate claims involving an intersection of New York’s Labor Law and federal regulations in the context of a construction site injury. If you or a loved one were hurt in a workplace accident, you may be owed damages, and it is smart to talk to a Syracuse personal injury attorney.
History of the Case
It is alleged that the plaintiff, a helicopter lineman employed by a subcontractor, was injured on June 18, 2021, during a construction project overseen by the defendant. The defendant was under contract to perform repair and construction work on power lines and had subcontracted certain tasks to another company. The plaintiff’s role required him to work from a platform attached to a helicopter to access and repair sections of power lines. While performing his duties, the helicopter’s rotor reportedly came into contact with the structure, causing it to spin out of control and crash, leading to serious injuries.
Reportedly, the plaintiff filed a lawsuit alleging violations of New York Labor Law §§ 200, 240, and 241(6), as well as negligence on the part of the defendant as the general contractor. In response, the defendant moved to dismiss the complaint, asserting that the claims were preempted by the Federal Aviation Act (FAA) and its implementing regulations. The trial court denied the motion, determining that the FAA did not preempt the plaintiff’s claims because the helicopter functioned as construction equipment rather than an aircraft engaged in aviation activities. The defendant appealed.
Federal Preemption in Personal Injury Cases
The court reviewed the defendant’s preemption argument under established principles of federal preemption law. The court reiterated that federal preemption occurs when Congress expressly preempts state law, legislates comprehensively to occupy an entire regulatory field, or when state law conflicts with federal regulations. While federal authority over air safety is extensive, the court emphasized that not all claims related to aviation are preempted.
In this case, the court found that the plaintiff’s claims were rooted in New York’s occupational health and safety laws, specifically Labor Law § 240, which places responsibility for worker safety on construction site owners and general contractors. The court determined that these laws were within the state’s historic police powers and did not conflict with federal air safety regulations. It noted that the helicopter’s role in this context was akin to a crane or bucket truck, as it was used to position the plaintiff for construction work rather than for aviation purposes.
Additionally, the court observed that the plaintiff’s claims did not challenge the operation or training of the helicopter or its pilot, areas typically governed by federal regulations. Instead, the claims focused on the defendant’s failure to provide adequate safety measures for a worker facing elevation-related hazards. The court concluded that there was no substantive conflict between New York’s Labor Law and the FAA, affirming the trial court’s denial of the defendant’s motion to dismiss.
Consult a Capable Syracuse Personal Injury Attorney
If you sustained workplace injuries, you may be able to pursue claims for your losses, and it is in your best interest to consult an attorney. The capable Syracuse personal injury attorneys of DeFrancisco & Falgiatano Personal Injury Lawyers are here to help. You can contact us to arrange a confidential and free conference by using our form online or calling us at 833-200-2000.