Green v. Evergreen Family Ltd. Partnership
Plaintiff Bradford Green initiated an action to recover damages for injuries sustained from a fall off an A-frame ladder while working on a car wash overhead door. The defendants, Evergreen Family Limited Partnership, moved for summary judgment, arguing plaintiff's activity was not covered by Labor Law § 240 (1) or that plaintiff was the sole proximate cause of his injuries. Plaintiff cross-moved for partial summary judgment on liability and dismissal of the sole proximate cause defense. The Supreme Court denied both motions regarding the Labor Law § 240 (1) claim but granted plaintiff's motion on the 14th affirmative defense. The Appellate Division affirmed, finding triable issues of fact concerning whether the work constituted routine maintenance or a repair, and the adequacy of the safety device provided, thus precluding a sole proximate cause defense as a matter of law.