In Quattrocchi v. F.J. Sciame Constr. Co., Inc, 11 NY3d 757 [2008] the plaintiff alleged that he was struck by falling planks that had been placed over open doors as a makeshift shelf to facilitate the installation of an air conditioner above a doorway. Upon plaintiffs appeal from a denial of summary judgment, the Court of Appeals affirmed the order and explained as follows: As our holding in Outar v. City of New York indicates, "falling object" liability under Labor Law 240(1) is not limited to cases in which the falling object is in the process of being hoisted or secured ...We agree with the Appellate Division majority that triable questions of fact preclude summary judgment on plaintiff's Labor Law 240(1) claim, including whether the planks were adequately secured in light of the purposes of the plank assembly and whether plaintiff caused the accident by jostling the doors after disregarding a warning not to enter the doorway area. Accordingly, the Appellate Division properly modified Supreme Court's order to the extent of denying partial summary judgment on plaintiff's Labor Law 240(1) claim.