KING, III, JOSEPH v. MALONE HOME BUILDERS, INC.
Plaintiff Joseph King III commenced this Labor Law action against Malone Home Builders, Inc., seeking damages for injuries from a fall through an unguarded stairwell during construction. King moved for partial summary judgment on liability under Labor Law § 240 (1) and to dismiss the defendant's special employee defense, which claimed workers' compensation as the sole remedy. The Supreme Court conditionally granted King's motion for liability but denied the dismissal of the special employee defense, citing a factual dispute. On appeal, the Appellate Division, Fourth Judicial Department, modified the Supreme Court's order. The Appellate Division granted King's motion in its entirety, dismissing the defendant's special employee defense based on collateral estoppel from a prior Workers' Compensation Board determination, and affirmed the partial summary judgment on Labor Law § 240 (1) liability for the plaintiff.