KUHN, JAMES C. v. CAMELOT ASSOCIATION, INC.
Plaintiff James C. Kuhn, an employee, sustained injuries when a Gradall forklift tipped over while he was working on the roof of a building owned by defendant Camelot Association, Inc. He initiated a Labor Law and common-law negligence action. The Supreme Court granted his motion for partial summary judgment on the Labor Law § 240 (1) claim and denied the defendant's cross-motion for summary judgment. Upon reargument, the Supreme Court adhered to its prior decision. The Appellate Division affirmed the order, concluding that the plaintiff had established the absence of necessary safety devices and that the defendant failed to create a triable issue of fact regarding whether the plaintiff's own conduct was the sole proximate cause of his injuries. A dissenting opinion argued that a triable issue of fact existed, as the plaintiff had access to a ladder but chose to use the forklift.