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Ruiz v. Roosevelt Terrace Coop., Inc.

Citation: 2023 NY Slip Op 00189Docket: Index No. 22868/18E Appeal No. 17105 Case No. 2021-03872

Court: Appellate Division of the Supreme Court of the State of New York; January 16, 2023; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case Ruiz v. Roosevelt Terrace Cooperative, Inc. involved a personal injury claim where the plaintiff, a construction worker, suffered electrocution while performing demolition work. The Appellate Division reviewed a lower court's decision that had granted partial summary judgment in favor of the plaintiff under Labor Law § 241(6) and denied a motion by the defendant, DJM NYC, LLC, to dismiss a claim under Labor Law § 200. The electrocution incident was attributed to a potential contact with a live electrical conduit, although evidence suggested alternative causes such as a loose wire. Due to these conflicting accounts, the appellate court found a triable issue of fact, reversing the summary judgment for the Labor Law § 241(6) claim. However, the court affirmed the denial of DJM's motion to dismiss the Labor Law § 200 claim, as there remained a factual question about DJM's role in ensuring the electricity was turned off. The court's ruling, which involved modifying the previous order to deny the summary judgment and affirming the dismissal denial, emphasized the critical examination of evidence to determine liability in workplace injuries, with no costs awarded.

Legal Issues Addressed

Labor Law § 200 Claim

Application: The court upheld the denial of DJM NYC, LLC's motion to dismiss the Labor Law § 200 claim, as there was a factual issue about whether DJM's actions related to the electricity contributed to the accident.

Reasoning: Conversely, the court upheld the denial of DJM NYC's motion to dismiss the Labor Law § 200 claim, noting that a factual issue existed regarding whether DJM's failure to ensure the electricity was turned off contributed to the accident.

Labor Law § 241(6) Liability

Application: The court reversed the partial summary judgment for Ruiz on the Labor Law § 241(6) claim due to conflicting evidence regarding the cause of electrocution, indicating a triable issue of fact.

Reasoning: Given these discrepancies, the court determined that there was a triable issue of fact regarding the circumstances of Ruiz's injury, leading to the reversal of the summary judgment on the Labor Law § 241(6) claim.

Proximate Cause in Workplace Injury

Application: The decision highlighted the necessity of establishing proximate cause in determining liability under the Labor Law, focusing on the role of DJM's actions in the incident.

Reasoning: The decision emphasized the importance of determining proximate cause in assessing liability under the Labor Law.