In Nunez v 672 Parkside, LLC (2026), the plaintiff was assigned to clean the first floor of a Brooklyn job site. While carrying a cabinet across the floor, he slipped on a sheet of metal covered in construction debris. The Supreme Court granted the owner and GC summary judgment and stuck to that ruling on renewal. The Second Department affirmed.
The holding has two parts:
- § 241(6): the debris was "an integral part of the work he was performing." That defeated the claim under 12 NYCRR 23-1.7(d) and (e)(2).
- § 200 and common-law negligence: the safe-place duty "does not extend to hazards that are part of, or inherent in, the very work the worker is performing." The plaintiff raised no triable issue on either.
Why it matters:
This is a reaffirmance, not a new law. But it is a clean, recent citable case that applies integral-to-the-work to both (d) and (e)(2) in one ruling.
One fact carried both claims: the assignment. His job included clearing debris from that specific area, and he was injured in the normal course of that work. Lock it down through the plaintiff, his foreman, and the employer's scope of work.
The defense held even though he was carrying a cabinet and not sweeping when he fell. Frame the task as the whole cleanup assignment, not what he was doing at that moment.

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