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Green v. Ebsary Foundation Co.

Citations: 920 So. 2d 127; 2006 Fla. App. LEXIS 686; 2006 WL 168000Docket: No. 3D04-2770

Court: District Court of Appeal of Florida; January 24, 2006; Florida; State Appellate Court

Narrative Opinion Summary

Affirmation of the lower court's decision is noted, referencing Roberts v. Dacra Design Assocs. Ltd., which establishes that independent contractors must expect potential hazards on construction sites. In Parrish v. Matthews, it was determined that if an injury occurs while the plaintiff is addressing a condition they were hired to correct, summary judgment in favor of the defendant is appropriate. Additionally, McCarty v. Dade Div. of Am. Hosp. Supply holds that if an employee is injured due to conditions the independent contractor is tasked with remedying, third-party liability cannot be established since the employee is presumed to have notice of those unsafe conditions.

Legal Issues Addressed

Independent Contractor Assumption of Risk

Application: Independent contractors are expected to anticipate and navigate potential hazards inherently associated with construction sites.

Reasoning: Affirmation of the lower court's decision is noted, referencing Roberts v. Dacra Design Assocs. Ltd., which establishes that independent contractors must expect potential hazards on construction sites.

Summary Judgment in Favor of Defendant

Application: When an injury occurs while the plaintiff is addressing a condition they were hired to correct, the court may grant summary judgment for the defendant.

Reasoning: In Parrish v. Matthews, it was determined that if an injury occurs while the plaintiff is addressing a condition they were hired to correct, summary judgment in favor of the defendant is appropriate.

Third-Party Liability and Notice of Unsafe Conditions

Application: An employee injured due to conditions they were hired to remedy cannot establish third-party liability as they are presumed to have been aware of the unsafe conditions.

Reasoning: Additionally, McCarty v. Dade Div. of Am. Hosp. Supply holds that if an employee is injured due to conditions the independent contractor is tasked with remedying, third-party liability cannot be established since the employee is presumed to have notice of those unsafe conditions.