Simmons v. City of New York
Glenn Simmons, a plumber, was injured while moving a 600-pound air compressor on a pallet jack at a construction site at the North Shore Marine Transfer Station in Queens. The pallet jack allegedly struck concrete debris, causing the compressor to roll off and injure Simmons' ankle. Simmons commenced an action against the City of New York, the Department of Sanitation, and Prismatic Development Corp., alleging violations of Labor Law §§ 200, 240(1), and 241(6), as well as common-law negligence. The Supreme Court denied Simmons' motion for summary judgment and granted the defendants' motion to dismiss the complaint. On appeal, the Appellate Division affirmed the Supreme Court's denial of Simmons' summary judgment motion on Labor Law § 240(1) and affirmed the dismissal of Labor Law § 240(1) claims against all defendants, and Labor Law § 200 and common-law negligence claims against the City defendants. However, the Appellate Division modified the Supreme Court's order by denying summary judgment to Prismatic Development Corp. on the Labor Law § 200 and common-law negligence claims, finding triable issues of fact. It also denied summary judgment on the Labor Law § 241(6) cause of action predicated on 12 NYCRR 23-2.2 (d), concluding that the defendants failed to demonstrate its inapplicability or lack of violation, or that a violation was not a proximate cause of the plaintiff's injuries.