12 TO 18 INCH FALL SUPPORTED SUMMARY JUDGMENT IN FAVOR OF PLAINTIFF UNDER LABOR LAW 240 (1).
The First Department determined a fall of 12 to 18 inches sufficed to award plaintiff summary judgment Labor Law 240 (1) action:
Plaintiff was injured when, while carrying wood planks, he fell through an opening in a latticework rebar deck to a plywood form that was 12 to 18 inches below. “There is no bright-line minimum height differential that determines whether an elevation hazard exists” … , and here, the record establishes that plaintiff's fall was the result of exposure to an elevation related hazard … . Brown v 44 St. Dev., LLC, 2016 NY Slip Op 02527, 1st Dept 3-31-16
LABOR LAW (12 TO 18 INCH FALL SUPPORTED SUMMARY JUDGMENT IN FAVOR OF PLAINTIFF UNDER LABOR LAW 240 (1))