Munoz v. DJZ Realty, LLC
Larry Munoz, an injured plaintiff, appealed a Supreme Court order that had granted summary judgment to defendant DJZ Realty, LLC, dismissing his Labor Law § 240 (1) cause of action. Munoz fell from a ladder while installing a poster on a billboard, arguing this activity constituted 'altering' a structure, a protected activity under the Labor Law. The appellate court modified the lower court's order, denying the defendant's motion for summary judgment on that claim. The court reasoned that the defendant failed to prove, as a matter of law, that applying a new advertisement to a billboard was mere routine maintenance rather than an alteration or repair. A dissenting opinion contended that such an activity was routine maintenance and not a 'significant physical change' to the structure, and therefore should not be covered by Labor Law § 240 (1).