Gutkaiss v. Delaware Ave. Merchants Group, Inc.
Plaintiff Timothy Gutkaiss, an independent contractor, was injured when he fell from a ladder while replacing decorative LED light strands on poles along Delaware Avenue. He initiated an action against Delaware Avenue Merchants Group, Inc. and the City of Albany, alleging violations of Labor Law § 240 (1) and negligence. The Supreme Court granted plaintiff's motion for partial summary judgment on the Labor Law claim and denied the City's cross-motion for summary judgment. On appeal, the Appellate Division, Third Department, reversed the Supreme Court's decision regarding the Labor Law § 240 (1) claim, determining that replacing decorative light strands constituted routine maintenance, not a 'repair' or 'construction' within the statute's protection, and that decorative lights were not 'fixtures'. However, the Appellate Division affirmed the denial of the City's cross-motion to dismiss the negligence claim, finding that the City was not entitled to qualified immunity for negligent maintenance and that its argument regarding lack of prior written notice was unpreserved for review.