Joseph Chiaravalloti v. Freedom Mortgage Corporation

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 3, 2025
DocketA-2965-22
StatusUnpublished

This text of Joseph Chiaravalloti v. Freedom Mortgage Corporation (Joseph Chiaravalloti v. Freedom Mortgage Corporation) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph Chiaravalloti v. Freedom Mortgage Corporation, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2965-22

JOSEPH CHIARAVALLOTI and KIMBERLY CHIARAVALLOTI, his wife,

Plaintiffs-Appellants,

v.

FREEDOM MORTGAGE CORPORATION, G&M INVESTMENTS LLC %SUITE3, G&M INV SUITE 3, G AND M INVESTMENTS LLC, and/or G & M INVESTMENTS LLC, G & M INVESTMENTS II LLC, and SRMG ENTERPRISES, LLC,

Defendants-Respondents,

and

ARCHWELL SOLUTIONS LLC,

Defendant. ____________________________

Argued May 1, 2024 – Decided March 3, 2025

Before Judges Gummer and Walcott-Henderson. On appeal from the Superior Court of New Jersey, Law Division, Camden County, Docket No. L-0814-21.

Richard T. Astorino argued the cause for appellants (Kotlar, Hernandez & Cohen, LLC, attorneys; Richard T. Astorino, of counsel and on the briefs).

Joseph F. Skinner argued the cause for respondent Freedom Mortgage Corporation (Kirmser, Lamastra, Cunningham & Skinner, attorneys; Joseph F. Skinner, of counsel and on the brief; Laura P. Baker, on the brief).

James J. Law argued the cause for respondents G and M Investments, LLC1 and SRMG Enterprises, LLC (Dengler & Lipski, attorneys; James J. Law, of counsel and on the brief).

The opinion of the court was delivered by

GUMMER, J.A.D.

While working as a self-employed elevator mechanic, plaintiff Joseph

Chiaravalloti2 was injured when he fell from an allegedly faulty ladder he was

required to use to access parts of the elevators he was servicing in a building

owned by defendant G&M and leased by defendant Freedom Mortgage

1 In its answer to the complaint, defendant G and M Investments, LLC (G&M) indicated plaintiffs had misidentified defendant in the complaint as "G&M Investments LLC %Suite 3" and "G & M Investments II LLC." 2 Kimberly Chiaravalloti, who is Joseph Chiaravalloti's wife, is also a plaintiff in this case. For ease of reading, we refer to Joseph Chiaravalloti as "plaintiff." A-2965-22 2 Corporation (Freedom). The court granted defendants' summary-judgment

motions, finding defendants were not liable because the fall occurred as a result

of "an operational hazard obvious and visible" to plaintiff that was part of the

work he had been hired to perform. Because the court misapplied a narrow

exception to the general rule imposing liability for the failure to provide a

reasonably safe work place, we reverse those orders and a subsequent order

denying plaintiffs' reconsideration motion.

I.

We draw these facts from the summary-judgment record, "view[ing] the

evidence in the light most favorable to [plaintiffs,] the non-moving part[ies]."

Comprehensive Neurosurgical, P.C. v. Valley Hosp., 257 N.J. 33, 71 (2024)

(first alteration in original) (quoting Qian v. Toll Bros., Inc., 223 N.J. 124, 134-

35 (2015)).

At the time of the accident, plaintiff worked as an elevator mechanic. He

was employed by Advanced Elevator Services, LLC (AES), a company he had

created, owned, and operated. In 2012, AES and G&M entered into an "Elevator

Maintenance Agreement," in which AES agreed to provide maintenance for two

hydraulic passenger elevators located in a building owned by G&M and leased

by Freedom. In the Agreement, AES agreed to provide "periodic examination,

A-2965-22 3 lubrication and adjustment" of certain parts of the elevators and to "make

necessary adjustment and repairs" to certain parts "when conditions warrant."

Paragraph 3 of the Agreement contained a list of items not covered by the

Agreement and for which AES was not responsible, including light fixtures and

lamps. Before the fall, plaintiff serviced the elevators in the building on a

monthly basis.

On March 21, 2019, plaintiff entered the elevator shaft in the building to

perform a maintenance task in the elevator pit area. The elevator pit was located

underneath the elevators below the first floor. To access the elevator pit,

plaintiff had to use an "access ladder" to descend to the bottom of the pit.

According to plaintiff, on the day of the accident while he was "[u]sing the

access ladder provided by the building, an obstruction in the ladder rung caused

the footing on the access ladder to be inadequate which caused [him] to lose

[his] own footing and slip off the access ladder." Plaintiff "held onto the ladder

with [his] right hand and arm only, for as long as [he] could. Then [he] dropped

approximately four feet to the concrete floor below and landed on his feet."

Plaintiff identified the hazardous condition as "an obstruction and a

protrusion including a light fixture. It was also a construction defect." Plaintiff

described the ladder and light fixture as follows:

A-2965-22 4 Approximately two feet below the top of the ladder is a mounting point that they mount this metal ladder to the building beam . . . . Below that, they had mounted . . . prior to our company being there. . . . a light fixture that was mounted in the rung of the ladder under the beam, and that's what caused me not to have proper footing on the ladder.

Plaintiff "had prior problems with the light fixture being in the way."

Plaintiff described the "problems" he had previously experienced descending

into the pit as "[n]ot having proper footing." According to plaintiff, "[w]hen

you're on a ladder, you should be able to place your foot and the ladder rung in

the arch of your foot or just before your heel so you're secure when you move

to the next rung. That light fixture prohibited that." Plaintiff testified "[t]he

light fixture doesn't have to do with the elevator. It has to do with the building

side responsibilities . . . that was a building issue" and that "[a]nything electrical

that has to do with lighting or . . . other unrelated elevator devices, which a light

is not an elevator device, . . . is building responsibility."

Before the fall, plaintiff had reported the problem to "Ryan" and "Steve."

Ryan Kerner was the Freedom employee who normally met with plaintiff on his

visits and signed plaintiff's paperwork. He and Steve Delvisio were part of the

Freedom in-house maintenance crew. Plaintiff also had reported it "on the

paperwork that's signed after every visit." The record contains, for example, an

A-2965-22 5 AES service ticket dated April 28, 2018, with a handwritten note: "Notified

customer of oil & ladder issue." Freedom was identified as the "customer."

Kerner signed that service ticket as the customer.

The record also contains an AES service ticket dated March 21, 2019, the

day of the fall. That ticket indicates plaintiff was at the building to perform

routine service and inspections. A handwritten note on the ticket states: "pit

ladder issues 1 & 2 cars," "unknown" materials were needed to address that

issue, and "notified customer Ryan, Norman." Norman Zeller was the senior

vice president of facilities and corporate real estate for Freedom and was

responsible for maintenance within the building.

On March 19, 2021, plaintiffs filed a complaint against G&M, Freedom,

Archwell Solutions, LLC (Archwell), and SRMG Enterprises, LLC (SRMG).3

They alleged plaintiff, while lawfully present at the building, had "sustained

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Joseph Chiaravalloti v. Freedom Mortgage Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-chiaravalloti-v-freedom-mortgage-corporation-njsuperctappdiv-2025.