Attorney obtained summary judgment on behalf of a subcontractor in a wrongful death case. Plaintiff was the Estate of a deceased employee, a 40 year-old Hispanic mother of 5 and illegal immigrant. She was a drywall finisher, and she died two days after she crushed her head between a soffit and the guardrail of the scissor lift while operating a scissor lift on the construction site. Defendant was another drywall sub-contractor on the project who was sued for negligence because defendant allegedly failed to inspect, maintain and warn the deceased. The motion for summary judgment was based on the Plaintiff's failure to state a cause of action for negligence and, even if they could, the claim was barred under the state's worker's compensation Horizontal Immunity law. The Horizontal Immunity law requires the plaintiff to plead and prove gross negligence in order to avoid horizontal workers compensation immunity. The Court granted the motion for summary judgment because defendant owed no duty to Plaintiff and had no duty to inspect and warn.