Mullen v. Zoebe, Inc.
A New York City firefighter, Mullen, sustained a serious back injury while responding to a fire at Zoebe Inc.'s building, which had multiple fire and safety code violations. Mullen sued under General Municipal Law § 205-a, seeking damages. The core legal question was whether comparative fault, as outlined in CPLR article 14-A, could be applied to diminish a firefighter's recovery in such an action. The Court of Appeals affirmed the lower courts' decisions, ruling that comparative fault is incompatible with and undermines the protective intent of General Municipal Law § 205-a. This statute aims to place entire responsibility for injuries arising from safety violations on property owners, thereby protecting firefighters from additional, unavoidable hazards and ensuring full recovery.