Daniello v. Holy Name Church
The plaintiff, an employee of Kings Harbor Care Center, suffered injuries after slipping from an extension ladder while painting a school gym owned by Holy Name Church, for which he received workers' compensation benefits. He subsequently sued Holy Name Church under Labor Law § 240 (1) for failing to provide safety devices, and Holy Name brought a third-party action against Kings for indemnification and contribution. The trial court improperly granted summary judgment on liability to the plaintiff and the third-party plaintiff on oral applications without evidentiary support, contrary to CPLR 3212 (b). The Supreme Court, Appellate Division, reversed the judgment, vacated it, and remanded the matter for a new trial on all issues due to the procedural error. Additionally, the court affirmed that the plaintiff was not a "volunteer" outside the protection of Labor Law § 240 (1), as he was a paid employee directed to perform the work.