context: Courts in other states have repeatedly found that in the absence of actual control, a property owner owes no duty to a contractor or a contractor's employee who suffers injury from being electrocuted on the property owner's premises.
citation_a.signal: cf.
citation_a.identifier: 420 Fed.Appx. 358, 362
citation_a.parenthetical: holding that a general contractor owed no duty to an employee of a subcontractor to warn of dangers of electrocution
citation_a.sentence: Merritt v. Bethlehem Steel Corp., 875 F.2d 603, 605-07 (7th Cir.1989) (rejecting the claim of a contractor’s employee that the premises owner had a duty to deenergize the lines where the contractor worked); Wells v. Gen. Elec. Co., 807 F.Supp. 1202, 1211 (D.Md.1992) (finding an employer owed no duty to a contractor’s employee in the absence of “latent or concealed dangers” or “actual physical control over the work area”); Jackson v. Petit Jean Elec. Co-op., 270 Ark. 506, 606 S.W.2d 66, 68 (1980) (finding a utility had no duty to deenergize its lines or warn an electrical contractor of “obvious hazards which are an integral part of the work the contractor was hired to perform”); Durbin v. Culberson Cnty., 132 S.W.3d 650, 660-61 (Tex.Ct.App.2004) (finding that the defendant owed no duty to a contractor who was electrocuted while changing out light bulbs on an energized pole, despite the contractor’s argument that the defendant should have provided locked down switches); cf. Groover v. Camp Dresser & McKee Inc., 420 Fed.Appx. 358, 362 (5th Cir.2011) (holding that a general contractor owed no duty to an employee of a subcontractor to warn of dangers of electrocution); Edick v. Paul de Lima Co., Inc., 6 A.D.3d 864, 775 N.Y.S.2d 385, 386 (2004) (holding a company that serviced a coffee maker owed no duty to an employee who received an electric shock while attempting to clean the coffee maker).
citation_b.signal: no signal
citation_b.parenthetical: finding a utility had no duty to deenergize its lines or warn an electrical contractor of "obvious hazards which are an integral part of the work the contractor was hired to perform"
citation_b.sentence: Merritt v. Bethlehem Steel Corp., 875 F.2d 603, 605-07 (7th Cir.1989) (rejecting the claim of a contractor’s employee that the premises owner had a duty to deenergize the lines where the contractor worked); Wells v. Gen. Elec. Co., 807 F.Supp. 1202, 1211 (D.Md.1992) (finding an employer owed no duty to a contractor’s employee in the absence of “latent or concealed dangers” or “actual physical control over the work area”); Jackson v. Petit Jean Elec. Co-op., 270 Ark. 506, 606 S.W.2d 66, 68 (1980) (finding a utility had no duty to deenergize its lines or warn an electrical contractor of “obvious hazards which are an integral part of the work the contractor was hired to perform”); Durbin v. Culberson Cnty., 132 S.W.3d 650, 660-61 (Tex.Ct.App.2004) (finding that the defendant owed no duty to a contractor who was electrocuted while changing out light bulbs on an energized pole, despite the contractor’s argument that the defendant should have provided locked down switches); cf. Groover v. Camp Dresser & McKee Inc., 420 Fed.Appx. 358, 362 (5th Cir.2011) (holding that a general contractor owed no duty to an employee of a subcontractor to warn of dangers of electrocution); Edick v. Paul de Lima Co., Inc., 6 A.D.3d 864, 775 N.Y.S.2d 385, 386 (2004) (holding a company that serviced a coffee maker owed no duty to an employee who received an electric shock while attempting to clean the coffee maker).