What is the standard for holding a homeowner liable for injuries suffered by a construction contractor?

Plaintiff, a self-employed construction contractor who was hired to renovate a single-family home, was injured when a beam on which he was leaning gave way and he fell from the second floor to the ground. The Second Department dismissed plaintiff's suit against the homeowners, in Arama v. Fruchter, decided on April 17, 2007. Why? "[S]ingle-family homeowners who contract for construction services are exempt from liability unless they direct or control the work." In strictly construing "direct or control," the court gave short shrift to the fact that the homeowners had given instructions to plaintiff, and they had periodically inspected the work in progress.