Jackson v. Heitman Funds/191 Colonie, LLC

In Jackson v. Heitman Funds/191 Colonie, LLC (111 AD3d 1208 [2013]), where "plaintiff established that a membrane roll weighing between 600 and 800 pounds was hoisted by the roll carrier to a height of approximately 1 1/2 feet off the roof's surface at the time of the accident," the Third Department found "a significant elevation differential given its substantial weight and the powerful force it generated when it fell, so as to require a safety device as set forth in Labor Law 240 (1)" (id. at 1210).