Palermo v. 7 W. 21 LLC
The plaintiff, Frank Palermo, was injured while assisting a coworker in carrying a large wood form on a construction site. While the plaintiff rested his end of the form on vertical piping, his coworker unexpectedly lifted his side, causing the form to fall and strike the plaintiff's left foot. The plaintiff moved for summary judgment on his Labor Law § 240 (1) claim, which the Supreme Court denied. The Appellate Division affirmed the denial, citing factual issues regarding whether the activity involved an elevation-related risk requiring the wood form to be secured under Labor Law § 240 (1). Additionally, a factual question remained as to whether an appropriate safety device could have prevented the accident.