In Runner, the Court found that § 240(1) did apply to a circumstance where the plaintiff was injured while moving an 800-pound reel of wire down 4 steps, which the court found to be a "physically significant elevation differential.
Holding that defendants were liable under Labor Law § 240 for plaintiffs fall and injury occasioned by an allegedly defective sandblaster where such injuries were the foreseeable result of the failure to provide plaintiff with a safe scaffold or ladder while sandblasted a railway car from a ladder
Holding that owners/contractors are liable under Labor Law section 240 where they failed to provide any safety devices for workers at a building site, and the absence of such devices is the proximate cause of injury to a worker"
In Wilinski, the plaintiff was injured when demolition debris fell from a wall near the plaintiff's work site causing two ten-foot high unsecured metal pipes to topple onto him from a height of about four feet.
In Gallagher v New York Post (14 NY3d 83), the Court of Appeals articulated the sole proximate cause defense as follows: "[l]iability under Section 240(1) does not attach when  the safety devices that plaintiff alleges were absent were readily available at the work site, albeit not in the immediate vicinity of the accident, and  plaintiff knew he was expected to use them  but for no good reason chose not to do so,  causing an accident.
In Felker, the plaintiff fell as he reached from a step ladder over an elevated alcove wall. It was this unique situation and the "contractor's complete failure to provide any safety device to plaintiff to protect him from this... risk of falling over the alcove wall and through the suspended ceiling to the floor below that leads to liability."