Caracciolo v. SHS Ralph, LLC
Richard Caracciolo, an elevator mechanic, allegedly sustained injuries during a construction project while working for Thyssenkrupp Elevator Corporation at premises owned by SHS Ralph, LLC, with Wilcox Development Corp. as the general contractor. He reportedly fell one story after stepping off an elevator platform onto an unconstructed mezzanine floor. Caracciolo filed a personal injury action, leading SHS Ralph to initiate a third-party action against Thyssenkrupp for contractual indemnification. Both SHS Ralph and Thyssenkrupp moved for summary judgment to dismiss the Labor Law § 240(1) cause of action and the third-party complaint. The Supreme Court denied these motions, and the Appellate Division affirmed, concluding that triable issues of fact existed regarding whether the absence of adequate safety devices was a proximate cause of the incident and whether Caracciolo's actions constituted the sole proximate cause of his injuries. The court also affirmed the denial of summary judgment for contractual indemnification, stating SHS Ralph failed to demonstrate it was free from negligence.