Lozada v. St. Patrick's R C Church
Plaintiff Edwin Lozada sustained injuries after falling from a ladder while installing a video surveillance system at a school owned by defendant St. Patrick's RC Church. Lozada commenced an action alleging a violation of Labor Law § 240 (1). He moved for summary judgment on the issue of liability, but the Supreme Court denied his motion, finding triable issues of fact regarding whether the ladder was secured and if his actions were the sole proximate cause of his injuries. The Appellate Division affirmed the Supreme Court's order, concluding that Lozada failed to establish a prima facie violation of Labor Law § 240 (1) due to conflicting testimony about the accident.