WOLFE, PHILLIP v. WAYNE-DALTON CORPORATION
Phillip Wolfe, a warehouse manager, sustained injuries after falling from a safety ladder while attempting to repair an overhead receiving door cable. He initiated an action against the warehouse owners, including Joanne Leska and Robert Tarson, Jr., alleging a violation of Labor Law § 240 (1). The Supreme Court initially granted Wolfe partial summary judgment on liability, deeming the activity a protected "repair." On appeal, the Appellate Division, Fourth Judicial Department, modified the Supreme Court's order, affirming that Wolfe was engaged in a protected activity but finding a triable issue of fact regarding whether the injury was due to an elevation-related risk under the statute. The appellate court also affirmed the dismissal of the defendants' immunity defense under Workers’ Compensation Law §§ 11 and 29 (6) and upheld the denial of their motion for leave to renew.