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Robinson v. East. Med. Ctr. LP - Case Brief Summary (New York)

In Robinson v East Med. Ctr., LP, 6 NY3d 550 [2006] the plaintiff was injured when he used a six-foot ladder for a job that he knew required an eight-foot ladder. The plaintiff was also aware that there were eight-foot ladders available at the job site.

The Court of Appeals held that the plaintiff was the sole cause of his injuries as a matter of law, stating that "plaintiff's own negligent actions -- choosing to use a six-foot ladder that he knew was too short for the work to be accomplished and then standing on the ladder's top cap in order to reach the work -- were, as a matter of law, the sole proximate cause of his injuries" (id. at 555).

The Court found that the plaintiff was the sole proximate cause of his accident because he knowingly chose to use a ladder that was too short for the task, despite the availability of taller ladders on site, and because he misused the shorter ladder by standing on its top cap.

In "knew that he needed an eight-foot ladder. . . . He acknowledged that there were eight-foot ladders on the job site, that he knew where they were stored, and that he routinely helped himself to whatever tools he needed rather than requesting them from the foreman.... Yet plaintiff proceeded to stand on the top cap of a six-foot ladder, which he knew was not tall enough for this task, without talking to the foreman again, or looking for an eight-foot ladder beyond his immediate work location.

In short, there were adequate safety devices eight foot ladders available for plaintiff's use at the job site." (Robinson, 6 NY3d at 554-555). The Court of Appeals held that "plaintiff's own negligent actions -- choosing to use a six-foot ladder that he was knew was too short for the work to be accomplished and then standing on the ladder's top cap in order to reach the work -- were, as a matter of law, the sole proximate cause of his injuries" (Robinson, 6 NY3d at 555).

In making this determination, the Court noted that "plaintiff also conceded that his foreman had not directed him to finish the piping in the office suite before undertaking other tasks, and testified that there was sufficient other work to occupy him for the rest of the workday" (id.).

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