Albert v. Williams Lubricants, Inc.
Plaintiff Charles J. Albert, Jr. was injured in December 1997 when a ladder slid while he was installing lubrication equipment at a dealership owned by Northgate Ford, Inc., for which his employer, Midstate Fuel Storage Systems, was contracted by Williams Lubricants, Inc. Albert and his wife sued alleging violations of Labor Law §§ 200, 240 (1), § 241 (6), and common-law negligence. The Supreme Court dismissed the Labor Law § 200 claim and Northgate's cross-claim for indemnification but denied dismissal of claims under Labor Law §§ 240 (1) and 241 (6). The appellate court found that the plaintiff's misuse of the ladder, which was deemed an adequate safety device, was the sole proximate cause of his injuries, thus reversing the lower court's partial denial of summary judgment for the defendants. Consequently, all claims under Labor Law §§ 240 (1), 241 (6), and common-law negligence were dismissed, and the lower court's decision was modified and affirmed.