Justin King V. Anheuser Busch Companies, Inc. Case Study

IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR FORD COUNTY, ILLINOIS

JUSTIN WILLIAM KING, ) )
Plaintiff. ) ) )
v. ) )
Anheuser Busch Companies, Inc. ) )
Defendant. )
____________________________________)

COMPLAINT

Comes Now the plaintiff, Justin King, by and through his attorney, states as follows:

JURISDICTION AND VENUE

Plaintiff, for all times mentioned herein, was and is a resident of the County of Jackson, State of Missouri.

The cause of action took place in Ford County, Illinois.

This is an action for damages in excess of the minimal jurisdictional limits of this court.

This court has original jurisdiction “of all justiciable matters” under
On the occasion in question, Frank Cuellar, employee of Defendant, was operating his employer’s beer truck, traveling southbound on Interstate 57 in Ford County, Paxton, Illinois.
9. On the occasion in question, Defendant was traveling behind Plaintiff in the left hand lane of Interstate 57 when Plaintiff noticed Defendant’s lights flashing. Plaintiff moved over to the right hand lane to allow Defendant to pass, at which time he saw beer cases falling from Defendant’s truck towards him. Plaintiff swerved left in an attempt to avoid the beer cases when the accident occurred.
10. On or before the date in question, Defendant, Anheuser-Busch, negligently and in violation of proper safety standards failed to employ competent and careful employees to load, secure and inspect the cargo, resulting in the freight to disembark from the truck while in transit.
11. It was the duty of the Defendant to ensure safe and proper loading, securing and inspection of cargo prior to transit. Defendant breached that duty of due care by failing to use proper procedures and failed to ensure safe conditions for the shipment of their
As a direct and proximate cause of the negligent acts of Defendant Anheuser-Busch or its employees as set forth above, Plaintiff has incurred the following expenses for medical care and attention:
a. Physicians' fees: amount to be determined at trial;
b. Medical supplies, appliances, and medicine: amount to be determined at trial;
c. Hospitalization: amount to be determined at trial;
d. Physical therapy: amount to be determined at trial;
e. Nursing services: amount to be determined at trial;
All of the above charges are reasonable and customary in the City of Paxton, Ford County.
14. As a further result of the injuries sustained by Plaintiff, there is a reasonable probability that Plaintiff will require further medical care and attention and will incur future reasonable and necessary expenses for medical care and attention. Plaintiff’s doctors estimated over $100,000 in future medical bills, plastic surgery, and counseling to be incurred by Plaintiff.

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury.

PRAYER FOR