Pardo v. Bialystoker Center & Bikur Cholim, Inc.
The plaintiff appealed two orders from the Supreme Court, New York County. The first order, dated September 12, 2002, and the second, dated February 27, 2003, had denied the plaintiff's motion for partial summary judgment on liability under Labor Law § 240 (1) and precluded him from asserting Labor Law claims at trial concerning the alleged failure of defendants to secure a scaffold with "tie-ins." The appellate court modified the lower court's orders, vacating the provisions that barred the plaintiff from offering evidence regarding the defendants' alleged failure to use tie-ins. The court affirmed the orders in all other respects. It emphasized that under Labor Law § 240 (1), a plaintiff only needs to demonstrate that injuries were partially attributable to the defendant's failure to implement statutorily mandated safety measures to protect against elevation-related risks. The court also clarified that contributory negligence is irrelevant in such cases. The plaintiff's belated request to plead a violation of Industrial Code § 23-5.8 (g) was denied due to an unequivocal waiver of his Labor Law § 241 (6) cause of action.