New York Court of Appeals

Rodger A. Padula, Appellant v. Lilarn Properties Corporation, Respondent

December 1, 199484 N.Y.2d 519

Summary

The Court held that New York Labor Law §§240 and 241 are primarily conduct‑regulating provisions, so the law of the place of the tort—Massachusetts—governs the dispute, and affirmed the summary‑judgment dismissals. Justice Titone, in a separate concurrence, agreed with the result but rejected the majority's interest analysis, emphasizing the statute’s lack of extraterritorial effect.