Elkins v. Robbins & Cowan, Inc.
The plaintiff, Stephen Elkins, an iron welder, was injured on a construction site controlled by general contractor Robbins & Cowan, Inc., and his employer, subcontractor Vulcan Iron Works, Inc. Elkins fell from a steel beam while tightening bolts, asserting a lack of adequate safety devices, a violation of Labor Law § 240 (1). He sought partial summary judgment on liability, which the Supreme Court, Suffolk County, denied. On appeal, the order was reversed, and Elkins' motion was granted. The appellate court found that Robbins & Cowan, Inc. violated Labor Law § 240 (1) by failing to provide proper safety devices, which was the proximate cause of Elkins' injuries, despite arguments of concurrent causes.