Cardenas v. BBM Construction Corp.
The plaintiff, Jose Cardenas, was injured while installing a 500-pound beam, alleging violations of Labor Law §§ 240 (1) and 241 (6) against BBM Construction Corp., the general contractor. The Supreme Court granted summary judgment dismissing both causes of action for BBM Construction and denied the plaintiff's cross-motion. The Appellate Division modified the Supreme Court's order, affirming the dismissal of the Labor Law § 240 (1) claim because the injury was not due to an elevation-related hazard. However, it reversed the dismissal of the Labor Law § 241 (6) claim, which was predicated on an alleged violation of 12 NYCRR 23-2.3 (a), as BBM Construction failed to prima facie demonstrate its inapplicability or non-violation. The plaintiff's cross-motion for summary judgment on the Labor Law § 241 (6) claim was denied due to remaining factual issues.