Marcella Dixon claims that a "certain inequality" between two slabs of concrete caused her to trip and fall forcefully onto a Belleville sidewalk.
Seeking in excess of $15,000 for a right shoulder injury, Dixon filed suit May 13 in St. Clair County against the city, county and Public Building Commission.
Dixon is represented by Del Goldenhersh of Belleville.
The incident took place June 7, 2004, just north of parking meter F102 near the intersection of North 1st and West Main streets.
According to Dixon, the defendants allowed the sidewalk to remain in a poor state of repair.
"The southernmost slab was higher than the northernmost slab as they were in proximity to one another just north of parking meter F102," the suit states.
Dixon claims she was thrown forcefully onto the sidewalk when she tripped, sustaining severe, permanent and progressive injuries.
She had to undergo a shoulder arthroscopy with open decompression, distal clavicle excision and rotator cuff repair.