Liverpool v. S.P.M. Environmental Inc.
Plaintiff sought summary judgment on liability under Labor Law § 240 (1) after the decedent, Keith Liverpool, died from a 15-foot fall at a construction site caused by unsecured bar joists. The Supreme Court, Bronx County, denied the motion. The appellate court unanimously reversed, granting summary judgment on liability against defendants S.P.M. Environmental Inc., the general contractor, and Provech Realty Co., the owner. The court emphasized the absolute liability under Labor Law § 240 (1), ruling that arguments of comparative negligence or the decedent's employment status as an independent contractor were irrelevant to the defendants' statutory duty to provide proper safety devices.