Calle v. City of New York
The plaintiff, a laborer at a construction site, sustained personal injuries after falling into an excavation. He commenced an action against the City of New York, alleging common-law negligence and violations of Labor Law §§ 200, 240 (1), and 241 (6). The Supreme Court denied the City's motion for summary judgment. On appeal, the Appellate Division, Second Department, reversed the Supreme Court's order, granting the City's motion for summary judgment. The court found that the plaintiff's own actions were the sole proximate cause of his injuries, as he used a wooden cross brace not intended as a walkway instead of provided ladders. Additionally, the court determined that the cited Labor Law regulations were inapplicable or not violated, and the City neither created nor had actual or constructive notice of a dangerous condition, thus dismissing the common-law negligence and Labor Law § 200 claims.