Van Guilder v. Sands Hecht Construction Corp.
This case involves an appeal from a judgment in an action under Labor Law § 240 (1). The judgment, entered April 12, 1996, awarded damages for past pain and suffering and past lost earnings, but zero for future damages. The court unanimously affirmed the judgment. The central issue was whether the trial court correctly instructed the jury on mitigation of damages, specifically regarding the plaintiff's refusal to undergo a myelogram, a test repeatedly recommended by his treating orthopedist for diagnosis and potential surgery. The appellate court found ample evidence to justify the mitigation charge, citing the physician's recommendation and the plaintiff's failure to attend physical therapy or seek employment. The court also affirmed the damage award, finding it reasonable given conflicting medical testimony about a herniated disc and inconsistencies in the plaintiff's testimony about his post-accident lifestyle and efforts to find work.