David Glazer (Partner-New York, NY) and Christian Balodis (Associate-New York, NY) coauthored the article “When Is Work ‘Work’? Dibrino, Calix and the Narrowing of Contractual Indemnity,” published as a preview by the New York State Bar Association on October 6, 2026. The article examines how two recent New York decisions ‒ Dibrino v. Rockefeller Center North, Inc. and Calix v. Union Theological Seminary in the City of New York ‒ have narrowed when broadly worded contractual indemnification provisions are triggered. The authors examine how the decisions shift the focus from an injured worker’s general connection to a project, including employment, site presence, or equipment ownership, to whether the specific condition that caused the injury arose from the proposed indemnitor’s actual contractual work. The decisions bring the First Department in line with the stricter approach previously applied in the Second and Third Departments, with significant implications for litigation strategy, discovery, settlement negotiations, and drafting of indemnification provisions. David and Christian explain that these case results are particularly significant for practitioners in the First Department, where courts previously took a broader approach to contractual indemnity. They also discuss how the decisions will change the way indemnity disputes are analyzed going forward, requiring closer attention to the specific condition that caused the injury and which contractor’s work produced it, pointing out that “Indemnity disputes that were once resolved by pointing to the proposed indemnitor’s project involvement will now turn on the granular question of which contractor’s work produced the specific condition that caused the injury.”