Marquez v. L & M Development Partners, Inc.
The plaintiff, an injured laborer, filed a personal injury lawsuit following a fall at a construction site, alleging Labor Law violations and common-law negligence against multiple parties, including Pro Safety Services, LLC (PSS), a safety consultant. PSS sought summary judgment to dismiss claims against it and for judgment on its own cross-claims. The Supreme Court initially denied PSS's motion. On appeal, the order was modified. The appellate court granted PSS summary judgment, dismissing the plaintiff's Labor Law and common-law negligence causes of action against PSS, and also dismissed various contribution and common-law indemnification claims against PSS, finding PSS lacked supervisory control. However, the denials of PSS's motion concerning contractual indemnification and failure to procure additional insured status were affirmed due to PSS's failure to meet its prima facie burden. The order was affirmed as modified on appeal.