In Sanatass v. Consolidated Investing Co., Inc., (10 NY3d 333 [2008]), the Court of Appeals recently held that an owner can be held liable under Labor Law 240(1) even though it had no notice of, or control over, the injury producing work. In reaching this conclusion, the Court relied on its earlier precedents which, "articulated a 'bright line rule' that section 240(1) applied to all owners regardless of whether the property was leased out and controlled by another entity or whether the owner had the means to protect the worker." (10 NY3d at 340.)