Wolfanger v. Once Again Nut Butter Collective Inc.
Plaintiff Lance Wolfanger commenced a Labor Law and common-law negligence action seeking damages for injuries sustained while working on a warehouse construction project. He alleged that he experienced dizziness and fell from a boom lift exhausting noxious diesel fumes while spray-painting at a high elevation. The Supreme Court granted summary judgment to defendants, concluding that the injuries were not caused by an elevation-related risk. The Appellate Division, Fourth Department, reversed this decision, reinstating the plaintiff's causes of action under Labor Law § 240 (1). The appellate court found that the plaintiff's fall from the lift, caused by noxious fumes at an elevation, constituted an elevation-related risk, and that defendants failed to provide proper protection. The court granted plaintiff summary judgment on the issue of liability for the Labor Law § 240 (1) claims.