Staub v. William H. Lane, Inc.
Plaintiff, an employee of a subcontractor (third-party defendant), was injured while working on a building project and initiated an action against the general contractor (defendant) alleging negligence and Labor Law violations. The general contractor subsequently filed a third-party action against the subcontractor, seeking contractual indemnification based on an unsigned written proposal that referenced AIA Contract A401. The Supreme Court partially granted the general contractor's cross-motion for conditional indemnification. The subcontractor appealed this order. The appellate court found that material questions of fact remained regarding whether the parties had genuinely agreed to be bound by the indemnification provisions of AIA Contract A401, particularly because no formal contract was signed and the AIA contract itself was not provided to the general contractor. Consequently, the appellate court modified the lower court's order, denying the general contractor’s cross motion for summary judgment in its entirety.