Castillo v. TRM Contr. 626, LLC
The plaintiff, Noel Castillo, was injured after falling from an A-frame ladder while preparing a window for painting. He testified that the six- to eight-foot-tall ladder was in poor condition and had to be leaned against a wall in a closed position due to heavy boxes obstructing the workspace. The Supreme Court, Bronx County, granted Castillo's motion for partial summary judgment on Labor Law § 240 (1) liability. The Appellate Division, First Department, affirmed this decision, citing that a statutory violation is established when a ladder shifts, slips, or collapses, especially when workplace conditions prevent proper securement. The court found that prior cases involving electrical shocks were distinguishable, reaffirming liability for gravity-related falls from inadequately secured ladders.