Vasquez v. Cohen Bros. Realty Corp.
Plaintiff Theresa Vasquez brought this action against defendant Cohen Brothers Realty Corporation after her husband, David Vasquez, died during the course of his employment at a building managed by defendant. David Vasquez fell to his death from an exhaust duct after climbing out of a scissor lift while attempting to replace ceiling tiles. The plaintiff alleged defendant was liable under Labor Law § 240 (1) for failing to provide proper safety devices. Defendant cross-moved for summary judgment dismissing the claim and also moved for summary judgment arguing the action was barred by the exclusivity provision of the Workers’ Compensation Law. The Supreme Court denied both motions. On appeal, the order was modified to grant plaintiff conditional partial summary judgment on the Labor Law § 240 (1) claim and affirmed the denial of defendant's motion to dismiss based on the Workers' Compensation Law exclusivity provision, citing outstanding questions of fact regarding defendant's status as a special employer.