Houston v. State of New York
Cornelius Houston, Sr., an ironworker, sustained a traumatic brain injury when iron posts fell and struck him while working on a bridge replacement project. He and his wife (claimants) commenced a claim against the State of New York, alleging a violation of Labor Law § 240 (1). The claimants moved for summary judgment on the issue of liability, but the Court of Claims denied their motion. The Appellate Division affirmed the denial, ruling that the claimants failed to establish a prima facie case that the incident resulted from the absence or inadequacy of an enumerated safety device or to eliminate all triable issues of fact regarding the claimant's own conduct as the sole proximate cause.