Casalini v. Alexander Wolf & Son
Plaintiff Michael Casalini was allegedly injured at work on a renovation site when he slipped and fell on a pile of debris. The Supreme Court initially granted defendants' in limine motion and dismissed the complaint, citing a prior order that found no negligence by defendant Alexander Wolf & Son regarding the debris. The Appellate Division, First Department, reversed this decision, ruling that the motion in limine was effectively an untimely motion for summary judgment under CPLR 3212(a) and also premature under CPLR 4401 as plaintiffs were denied an evidentiary hearing. Consequently, the appellate court denied the motion, and the complaint was reinstated in its entirety.