Robert Arneman v. Republic of Turkey, et al.

CourtDistrict Court, S.D. New York
DecidedMarch 5, 2026
Docket1:22-cv-05701
StatusUnknown

This text of Robert Arneman v. Republic of Turkey, et al. (Robert Arneman v. Republic of Turkey, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert Arneman v. Republic of Turkey, et al., (S.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ROBERT ARNEMAN, Plaintiff, 22 Civ. 5701 (DEH) v. MEMORANDUM REPUBLIC OF TURKEY, et al., OPINION AND ORDER Defendants.

DALE E. HO, United States District Judge: Before the Court is the October 28, 2025 Report and Recommendation (the “Report” or “R&R”), ECF No. 121, issued by Magistrate Judge Netburn recommending that: The parties’ cross-motions as to Plaintiff’s claim under New York Labor Law § 241(6)) be denied; Defendant the Republic of Türkiye’s motion for summary judgment on Plaintiff’s claims under New York Labor § 200 and for his common-law negligence claim be granted; Defendant New York City Acoustics’ motion for summary judgment on Plaintiff’s claims under New York Labor Law § 200 and for common law negligence be denied; and The motions for summary judgment of Defendants IC ICTAS Construction (Turkevi) LLC and IC ICTAS US Inc. (“ICTAS Contractor”) be granted on all claims. See R&R at 1-2. For the reasons stated below, the well-reasoned Report is ADOPTED IN FULL. BACKGROUND Familiarity with the factual background and relevant procedural history of this case as set out in the Report is assumed. See generally R&R at 2-3. This action is assigned to Magistrate Judge Netburn for general pretrial supervision and report and recommendation on dispositive motions. See Order Referring Case to Magistrate Judge, ECF No. 45. On October 28, 2025, Magistrate Judge Netburn issued an R&R. See generally R&R. Only one set of objections was filed: by Plaintiff Robert Arneman as to Magistrate Judge Netburn’s recommendation that his motion for summary judgment on his claim under New York Labor Law § 241(6) be denied. See Plaintiff’s Objections to Report and Recommendation (“Pl.’s Obj.”), ECF No. 122. Defendants timely responded to Plaintiff’s objections. See Defendants’ Response to Plaintiff’s Objections to Report and Recommendation (“Defs.’ Resp.”), ECF No. 123. Plaintiff’s objections are the subject of this Memorandum Opinion and Order and, for the reasons

stated below, are overruled. LEGAL STANDARD When reviewing a Report and Recommendation, a court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1)(C). For dispositive matters, a district judge is required to “determine de novo any part of the magistrate judge’s disposition that has been properly objected to” by any party. Rule 72(b)(3).1 For those portions to which no proper objection is made, a district court need only satisfy itself that there is no “clear error on the face of the record.” Miller v. Brightstar Asia, Ltd., 43 F.4th 112, 120 n.4 (2d Cir. 2022). When a party has not properly made objections, for instance, by making “objections that

are merely perfunctory responses argued in an attempt to engage the district court in a rehashing of the same arguments set forth in the original papers[, it] will not suffice to invoke de novo review.” Owusu v. N.Y. State Ins., 655 F. Supp. 2d 308, 313 (S.D.N.Y. 2009). Accordingly, when a court is considering objections that “merely re-assert arguments already submitted to the Magistrate Judge, this Court need only review the Report and Recommendation for clear error.”

1All references to Rules are to the Federal Rules of Civil Procedure. In all quotations from cases, the Court omits citations, alterations, emphases, internal quotation marks, and ellipses, unless otherwise indicated. Id.; see also Pinkney v. Progressive Home Health Servs., 2008 WL 2811816, at *1 (S.D.N.Y. July 21, 2008) (“To the extent, however, that the party makes only conclusory or general objections, or simply reiterates the original arguments, the Court will review the Report strictly for clear error . . . . [N]o party [should] be allowed a ‘second bite at the apple’ by simply relitigating a prior argument.”); Vega v. Artuz, No. 97 Civ. 3775, 2002 WL 31174466, at *1 (S.D.N.Y. Sept. 30, 2002) (noting that if the district court engaged with objections that are “general and conclusory . . . [this]

would reduce the magistrate’s work to something akin to a ‘meaningless dress rehearsal’”). DISCUSSION I. Portions of the Report to which the Parties Did Not Object The parties do not object to the bulk of the Report’s recommendations. In reviewing a magistrate judge’s report and recommendation, a district judge “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1)(C). “In a case such as this one, where no timely objection has been made” to various recommendations in a Report, “a district court need only satisfy itself that there is no clear error on the face of the record” as to those portions of the Report. Kuan v. Notoriety Grp. LLC, No. 22 Civ. 1583, 2023 WL 3936749, at *1 (S.D.N.Y. June 9, 2023). The Court has reviewed the portions of the Report to which the parties did not object, and

has found no error, clear or otherwise. Accordingly, those portions of the Report are adopted in full. II. Plaintiff’s Claim under New York Labor Law § 241(6) Mr. Arneman objects to the Report’s recommendation that summary judgment be denied on his claim under New York Labor Law § 241(6). Because this objection is to a recommendation on a dispositive matter, the Court reviews it de novo. As the Report explains, and as no party disputes, New York Labor Law § 241(6) imposes a nondelegable duty upon owners, contractors, and their agents to “provide reasonable and adequate protection and safety for workers” and to comply with the specific safety rules promulgated by the Commissioner of the Department of Labor. Ross v. Curtis Palmer Hydro-Electric Co., 81 N.Y.2d 494, 501-02 (1993) (quotation marks omitted). To prevail on a § 241(6) claim, a plaintiff must show that his injury was proximately caused by a violation of a specific and concrete Industrial Code regulation. Zaino v. Rogers, 153 A.D.3d 763, 760 (2d Dep’t 2017) (citation omitted). A violation of an Industrial Code provision does not itself establish liability under § 241(6) but constitutes “some evidence which the jury may consider on the question of [] negligence.” Long v. Forest-Fehlhaber, 55N.Y.2d 154, 160 (1982). Report at 7-8. Mr. Arneman’s claim is premised on an alleged violation of New York Industrial Code § 23-1.7(e)(1) and (2), which provides, (1) Passageways. All passageways shall be kept free from accumulations of dirt and debris and from any other obstructions or conditions which could cause tripping. Sharp projections which could cut or puncture any person shall be removed or covered. (2) Working areas. The parts of floors, platforms and similar areas where persons work or pass shall be kept free from accumulations of dirt and debris and from scattered tools and materials and from sharp projections insofar as may be consistent with the work being performed. 12 N.Y.C.R.R. § 23-1.7(e)(1)-(2). The Report concluded that there are two disputes of fact that preclude summary judgment on this claim: first, whether the screw that Mr. Arneman stepped on and which caused his injuries was a “sharp projection” within the meaning of the New York Industrial Code; and second, whether the screw originated from Defendant City Acoustics’ work (in which case, the Report concluded, liability can also be imputed to Türkiye, as the duties imposed on owners under New York Labor Law § 241(6) are non-delegable). See Report at 7-10.

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Related

Owusu v. New York State Insurance
655 F. Supp. 2d 308 (S.D. New York, 2009)
Ross v. Curtis-Palmer Hydro-Electric Co.
618 N.E.2d 82 (New York Court of Appeals, 1993)
Zaino v. Rogers
2017 NY Slip Op 6218 (Appellate Division of the Supreme Court of New York, 2017)
Mooney v. BP/CG Ctr. II, LLC
2020 NY Slip Op 246 (Appellate Division of the Supreme Court of New York, 2020)
Miller v. Brightstar Asia, Ltd.
43 F.4th 112 (Second Circuit, 2022)

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Bluebook (online)
Robert Arneman v. Republic of Turkey, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-arneman-v-republic-of-turkey-et-al-nysd-2026.