Rohles v. Metropolitan Transp. Auth.

2024 NY Slip Op 30566(U)
CourtNew York Supreme Court, New York County
DecidedFebruary 23, 2024
StatusUnpublished

This text of 2024 NY Slip Op 30566(U) (Rohles v. Metropolitan Transp. Auth.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rohles v. Metropolitan Transp. Auth., 2024 NY Slip Op 30566(U) (N.Y. Super. Ct. 2024).

Opinion

Rohles v Metropolitan Transp. Auth. 2024 NY Slip Op 30566(U) February 23, 2024 Supreme Court, New York County Docket Number: Index No. 157185/2019 Judge: David B. Cohen Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 157185/2019 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 02/23/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. DAVID B. COHEN PART 58 Justice ---------------------------------------------------------------------------------X INDEX NO. 157185/2019 GREG ROHLES, MOTION SEQ. NO. 004 Plaintiff,

-v- METROPOLITAN TRANSPORTATION AUTHORITY, THE NEW YORK CITY TRANSIT AUTHORITY, DECISION + ORDER ON METROPOLITAN TRANSPORTATION AUTHORITY MOTION (CAPITAL CONSTRUCTION COMPANY), and JUDLAU CONTRACTING/TC ELECTRIC, A JOINT VENTURE,

Defendants. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 004) 116, 117, 118, 120, 121, 122, 123, 124, 125, 126, 127, 128, 129 were read on this motion to/for RENEW/REARGUE/RESETTLE/RECONSIDER .

In this Labor Law action, third-party defendant Rebar Steel Corp. moves, pursuant to

CPLR 2221(d), for leave to reargue defendants’ motion for summary judgment on the issue of

contractual indemnification (Seq. 003) and, upon reargument, for denial of defendants’ underlying

motion.

I. Factual and Procedural Background

As set forth in this Court’s June 7, 2023 order (NYSCEF Doc No. 111), this action arises

from an incident in March 2019 in which plaintiff was allegedly injured after being struck by an

excavation machine while working at a construction site in Manhattan. Plaintiff commenced this

action against defendants asserting claims for common-law negligence and violations of Labor

Law §§ 200, 240(1), and 241(6). Following joinder of issue, defendants commenced a third-party

action against Rebar Steel asserting claims of, among other things, contractual indemnification.

157185/2019 ROHLES, GREG vs. METROPOLITAN TRANSPORTATION Page 1 of 5 Motion No. 004

1 of 5 [* 1] INDEX NO. 157185/2019 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 02/23/2024

After the completion of discovery and the filing of a note of issue, plaintiff discontinued his Labor

Law § 240(1) claims against defendants.

Defendants then moved for summary judgment on the issue of contractual indemnification

against Rebar Steel, which Rebar Steel opposed. While that motion was pending, plaintiff

discontinued his Labor Law § 200 and common-law negligence claims against defendants

Metropolitan Transit Authority, The New York City Transit Authority, and Metropolitan Transit

Authority (Capital Construction Company) (collectively, the MTA defendants); leaving the Labor

Law § 200 and common-law negligence claims against defendant Judlau Contracting/TC Electric,

A Joint Venture (Judlau), intact (Doc Nos. 109-110).

By decision and order entered June 7, 2023, defendants’ motion was granted after it was

determined that they were entitled to unconditional contractual indemnification (NYSCEF Doc

No. 111). In reaching that determination, this Court indicated that plaintiff’s decision to

discontinue his claims of common-law negligence and violations of Labor Law §§ 200 and 240(1)

meant that the only question remaining was whether defendants were entitled to full, unconditional

contractual indemnification because they could only be found vicariously liable pursuant to Labor

Law § 241(6). Rebar Steel now moves for leave to reargue the motion for partial summary

judgment and, upon reargument, for an order denying the motion with respect to Judlau (Doc No.

116), which defendants oppose (Doc No. 121).

II. Legal Analysis and Conclusions

Rebar Steel contends that it is entitled to reargument because this Court overlooked facts

in granting Judlau unconditional contractual indemnification when it misread the stipulation

discontinuing plaintiff’s common-law negligence and Labor Law § 200 claims against the MTA

defendants to also apply to Judlau, causing this Court to incorrectly conclude that Judlau was

157185/2019 ROHLES, GREG vs. METROPOLITAN TRANSPORTATION Page 2 of 5 Motion No. 004

2 of 5 [* 2] INDEX NO. 157185/2019 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 02/23/2024

entitled to unconditional contractual indemnification because it could not be held directly liable.1

In opposition, defendants maintain, among other things, that no facts were overlooked in deciding

to grant their motion. Alternatively, they argue that if reargument is granted, they are still entitled

to conditional contractual indemnification.

“A motion for reargument, addressed to the discretion of the court, is designed to afford a

party an opportunity to establish that the court overlooked or misapprehended the relevant facts,

or misapplied any controlling principle of law. Its purpose is not to serve as a vehicle to permit

the unsuccessful party to argue once again the very questions previously decided” (Foley v Roche,

68 AD2d 558, 567 [1st Dept 1979] [citations omitted]; accord Mangine v Keller, 182 AD2d 476,

477 [1st Dept 1992]).

Here, Rebar Steel demonstrates that this Court overlooked a critical fact in deciding the

underlying motion. The stipulation discontinuing plaintiff’s claims of common-law negligence

and violations of Labor Law § 200 did not apply to all defendants, just the MTA defendants. Thus,

the common-law negligence and Labor Law § 200 claims as against Judlau were not discontinued,

and it was incorrect to conclude that Judlau could only be found vicariously liable under Labor

Law § 241(6). Therefore, Rebar Steel is granted leave to reargue Judlau’s motion for summary

judgment on the issue of contractual indemnification.

Upon reargument, Judlau is only entitled to conditional contractual indemnification. As

discussed in the June 2023 order, the subcontract between Judlau and Rebar Steel included a broad

indemnification provision requiring Rebar Steel to indemnify Judlau against claims “resulting

from, arising out of[,] or occurring in connection with” Rebar Steel’s work providing and installing

rebar. That provision was triggered by plaintiff’s injuries, which occurred while he was searching

1 Rebar Steel does not argue that the portion of the decision granting the MTA defendants unconditional contractual indemnification was improper, it only argues that the portion pertaining to Judlau was incorrect. 157185/2019 ROHLES, GREG vs. METROPOLITAN TRANSPORTATION Page 3 of 5 Motion No. 004

3 of 5 [* 3] INDEX NO. 157185/2019 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 02/23/2024

for rebar. Therefore, until a determination can be made regarding any purported negligence, Judlau

is entitled to conditional summary judgment on its contractual indemnification claim against Rebar

Steel (see Madkins v 22 Little W. 12th St., LLC, 191 AD3d 434, 436 [1st Dept 2021] [granting

conditional summary judgment on contractual indemnification, “subject to a determination

whether [defendant] was negligent,” because broad indemnification provision triggered by

plaintiff’s injuries]; Aramburu v Midtown W. B, LLC, 126 AD3d 498, 501 [1st Dept 2015]

[similar]).

Accordingly, it is hereby:

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Related

Aramburu v. Midtown West B, LLC
126 A.D.3d 498 (Appellate Division of the Supreme Court of New York, 2015)
Foley v. Roche
68 A.D.2d 558 (Appellate Division of the Supreme Court of New York, 1979)
Mangine v. Keller
182 A.D.2d 476 (Appellate Division of the Supreme Court of New York, 1992)

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2024 NY Slip Op 30566(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/rohles-v-metropolitan-transp-auth-nysupctnewyork-2024.