Schelble v. ADF Construction Corp.
Defendants and third-party plaintiffs, ADF Construction Corp. and Master Builders, Inc., sought summary judgment for contractual and common-law indemnification against third-party defendant Steelcor Builders. The Supreme Court erred in denying contractual indemnification, as the subcontract contained a broad indemnity clause, and General Obligations Law §5-322.1 did not preclude enforcement due to absolute liability under Labor Law § 240 (1). However, the denial of common-law indemnification was proper due to existing factual issues concerning ADF's control over worker safety. The appellate court modified the orders by granting summary judgment for contractual indemnification and otherwise affirmed the orders.