## Facts

- Rodger A. Padula, a New York domiciliary, worked for a New York subcontractor on a construction project at commercial property located in Massachusetts.
- Lilarn Properties Corporation, a New York corporation, owned the Massachusetts property.
- Padula fell from a scaffold at the Massachusetts worksite and suffered personal injuries.
- Padula sued in New York, asserting claims under New York Labor Law §§ 200, 240(1), and 241(6) and related regulations.
- The defendant moved for partial summary judgment dismissing the Labor Law causes of action on the ground that New York’s Labor Law does not govern an out-of-state accident.

## Issues

1. Under New York choice-of-law rules, does New York Labor Law §§ 200, 240(1), and 241(6) apply to a construction accident occurring in Massachusetts when the injured worker and property owner are New York domiciliaries?
2. Are these Labor Law provisions conduct-regulating rules that ordinarily are governed by the law of the place of the tort?

## Decision

- The Court of Appeals affirmed the dismissal of the New York Labor Law claims.
- Applying New York’s interest-analysis approach, the court held Massachusetts law governed because Massachusetts had the greater interest in regulating conduct at the in-state construction site.
- The court rejected the argument that New York’s worker-protective Labor Law should apply based solely on the parties’ New York domiciles.

## Legal Principles

- In tort conflicts, New York applies interest analysis to determine which jurisdiction has the greater interest in having its law applied, focusing on contacts that relate to the purpose of the conflicting laws.
- Interest analysis considers (1) the significant contacts and where they occurred and (2) whether the conflicting rules are conduct-regulating or loss-allocating.
- Conduct-regulating rules are typically governed by the law of the place where the tort occurred, because that jurisdiction has the primary interest in controlling behavior within its borders.
- New York Labor Law §§ 200, 240(1), and 241(6) are conduct-regulating workplace-safety statutes; they generally do not apply extraterritorially to injuries at out-of-state construction sites.

## Conclusion

Because the accident occurred in Massachusetts and the asserted New York Labor Law provisions regulate on-site conduct and safety, Massachusetts had the stronger governmental interest, and New York’s Labor Law §§ 200, 240(1), and 241(6) did not apply.


Padula v. Lilarn Props. Corp., 84 N.Y.2d 519 (N.Y. 1994)