Casilari v. Condon
Jose Casilari, an injured plaintiff, along with his wife derivatively, brought an action against Zachary F. Condon, the owner of a single-family home, after Casilari fell from a deck during renovations. The plaintiffs alleged violations of Labor Law §§ 200, 240, 241 (6), and common-law negligence. The Supreme Court initially dismissed the Labor Law §§ 240 and 241 (6) claims but denied summary judgment for the Labor Law § 200 and common-law negligence claims. On appeal, the Appellate Division, Second Department, reversed this decision, granting summary judgment to the defendant. The appellate court found the defendant established, prima facie, that he did not supervise the work and lacked notice of the dangerous condition, and the plaintiffs failed to raise a triable issue of fact, partly due to the Supreme Court's error in considering an undisclosed witness affidavit.