Marcellino v. Nigro
Plaintiff Anthony Marcellino sustained injuries after falling through an open stairwell while working as a bricklayer on a construction project owned by John J. Nigro and with Beltrone Construction Company, Inc. as the general contractor. Plaintiffs initiated a suit alleging negligence and violations of Labor Law §§ 240 (1) and 241-a, moving for partial summary judgment on liability. Defendants cross-moved for summary judgment on indemnification claims. The Supreme Court denied all motions. The Appellate Division affirmed the denials, finding Labor Law § 240 (1) inapplicable to a lack of planking and ruling that Labor Law § 241-a did not require planking at that specific level, while violations of administrative rules do not establish absolute liability due to potential contributory negligence. The court also affirmed the denial of indemnification as negligence by the contractor or subcontractor was not established.