DaSilva v. Super P57, LLC
The Appellate Division, First Department, modified a Supreme Court order regarding a Labor Law claim. Plaintiff Ivoir DaSilva was injured after falling from an unsecured plank, found to be 1.5 feet above an awning, due to an improperly designed fall prevention system lacking adequate tie-off points. The court rejected defendants' argument that DaSilva was the sole proximate cause, finding no evidence for a recalcitrant worker defense and the scissor lift argument unpreserved. Consequently, the court affirmed DaSilva's entitlement to partial summary judgment under Labor Law § 240 (1), deeming claims under Labor Law §§ 200 and 241 (6) academic.