MADISON - ST. CLAIR RECORD

David L. Hicks has filed suit against Charlotte N. Miller, alleging his neck and shoulder were injured after she collided with his vehicle.

Hicks was driving his Ford Focus north on Highway 159, about 500 feet north of Ashland Road in St. Clair County, on June 9, 2007, at 11 a.m. when the incident occurred, according to a complaint filed Nov. 5 in St. Clair County Circuit Court.

At the same time, Miller was stopped at Rally's in her 2001 Honda Civic and waiting to make a left-hand turn south onto Highway 159, the suit states.

Hicks claims Miller pulled out across the northbound lanes of traffic and collided with him.

In addition to his injuries, Hicks suffered severe pain, incurred medical costs in excess of $91,000 and lost the ability to enjoy and pursue his normal life activities, the suit states.

Miller had a duty to drive in a way that did not present a danger to Hicks, but breached that duty because she failed to keep a proper lookout, failed to yield the right of way, attempted to cross lanes of traffic when it was unreasonable to do so and failed to brake to avoid a collision, according to the complaint.

Hicks is represented by Joseph R. Dulle of Stone, Leyton and Gershman in St. Louis.

St. Clair County Circuit Court case number: 08-L-562.