In Dalanna v. City of New York (308 AD2d 400 [1st Dept 2003]), the First Department affirmed the dismissal of a Labor Law 200 claim which was brought by a plumber who was injured when he tripped over a bolt that protruded from a concrete slab. Prior to the day of the accident, a number of bolts had been used to temporarily anchor a tank to the slab before its permanent installation at another location. After the tank was removed, the plaintiff's employer was supposed to have cut all the bolts level with the surrounding surface. However, the plaintiff's employer neglected to cut the bolt on which the plaintiff tripped. The Court in Dalanna determined that the protruding bolt was not a defect inherent in the property, but instead, its presence was the result of the manner in which the plaintiff's employer performed its work. Therefore, even though the owner and construction manager had constructive notice of the bolt, they could be held liable under Labor Law 200 only if they had exercised supervisory control over the employer's work (id.).