Mammone v. T.G. Nickel & Associates, LLC
The plaintiff, a maintenance worker, fell from a ladder while attempting to change air filters at Garden City High School. He commenced an action against T.G. Nickel & Associates, LLC, the construction manager, alleging common-law negligence and violations of Labor Law §§ 200, 240 (1), and 241 (6). The Supreme Court granted summary judgment dismissing these causes of action against Nickel. On appeal, the Appellate Division, Second Department, affirmed the Supreme Court's order, finding that the plaintiff was not engaged in a protected activity under Labor Law § 240 (1), his accident did not involve construction, demolition, or excavation under Labor Law § 241 (6), and Nickel lacked authority to supervise or control the plaintiff's work for the Labor Law § 200 and common-law negligence claims.