Erkan v. McDonald's Corp.
Plaintiff Huseyin Erkan was injured when he fell from an unsecured ladder while installing tiles for a McDonald's restaurant, subsequently filing a lawsuit against McDonald's Corporation and Custom Commercial Construction Corp. alleging Labor Law violations. The Supreme Court initially denied his motion for partial summary judgment on the Labor Law § 240 (1) claim, citing prematurity. However, the Appellate Division, First Department, unanimously reversed this decision, granting the plaintiff's motion. The appellate court determined that the plaintiff established a prima facie case for liability under Labor Law § 240 (1) and the defendants failed to present admissible evidence to create a material issue of fact. It emphasized that unverified documents and unsworn statements were insufficient to oppose summary judgment, affirming that the owner or contractor's failure to provide proper protection leads to absolute liability unless the worker's actions were the sole proximate cause.