Ross v. Curtis-Palmer Hydro-Elec. Co

In Ross v. Curtis-Palmer Hydro-Elec. Co. 81 NY2d 494, 500-501, 618 N.E.2d 82, 601 N.Y.S.2d 49 (1993), the Court, in discussing the risks covered by the statute, stated that section 240: "Evinces a clear legislative intent to provide 'exceptional protection' for workers against the 'special hazards' that arise when the work site is itself elevated or is positioned below the level where 'materials or load are hoisted or secured.' The 'special hazards' to which we referred in Rocovich, however, do not encompass any and all perils that may be connected in some tangential way with the effects of gravity. Rather, the 'special hazards' referred to are limited to such specific gravity-related accidents as falling from a height or being struck by a falling object that was improperly hoisted or inadequately secured. In other words, Labor Law 240 (1) was designed to prevent those types of accidents in which the scaffold, hoist, stay, ladder, or other protective device proved inadequate to shield the injured worker from harm directly flowing from the application of the force of gravity to an object or person"