Striegel v. Hillcrest Heights Development Corp.
Plaintiff Robert Striegel sought partial summary judgment against Hillcrest Heights Development Corporation under Labor Law §§ 240(1) and 241(6) for injuries sustained from a fall while working on a sloped roof. Striegel, an employee of Sahlem's Roofing and Siding, slipped on a frost-covered sub-roof, fell, and slid down the roof, alleging that Hillcrest, as owner and general contractor, failed to provide safety devices. Defendants argued that the injury was from lifting or that the fall was onto the roof surface, not from an elevated height, citing White v Sperry Supply & Warehouse. The court distinguished White, finding that the sloped roof in this case made the fall directly related to gravity, thus falling within the purview of Labor Law § 240(1). Consequently, the court granted Striegel partial summary judgment on liability and also granted Hillcrest a conditional judgment for common-law indemnification against Sahlem’s, finding no active negligence on Hillcrest's part.