Becerra v. City of New York
This case concerns an appeal regarding a Labor Law § 240 (1) claim. The plaintiff, an employee of Volmar Construction, Inc., was injured on August 20, 1992, while engaged in demolition work at a City-owned building in the Bronx. He fell through an unsecured plywood platform on an elevated floor, with no safety devices provided to prevent a fall. The motion court initially denied the plaintiff's partial summary judgment motion on liability, citing factual issues regarding the fall and whether it constituted an elevation-related risk and proximate cause. However, the appellate court unanimously reversed this decision, holding that the unsecured plywood boards functioned as an elevated platform or scaffold, and their collapse constituted a prima facie violation of Labor Law § 240 (1). The court emphasized that falls through temporary floors or scaffolds are covered under this section, thus granting the plaintiff partial summary judgment on liability.