Herman Moore filed a Federal Employers' Liability Act complaint against BNSF Railway in Madison County Circuit Court Sept. 4, seeking damages in excess of $50,000.

According to Moore, he has been diagnosed with injuries to his low back. He claims that during his career with the railroad he was required to ride on and operate locomotive engines.

He claims BNSF failed to provide him a safe place to work, failed to provide safe conditions for work, failed to provide safe methods of work and failed to enact a comprehensive ergonomics program.

Moore further claims the railroad failed to warn or protect him from the danger of exposure to cumulative trauma, failed to provide an air rise seat, required him to work in defective seats and failed to provide adequate training.

"Defendant failed to follow the recommendations of its own internal group studying the issue of cumulative trauma," the complaint states.

He also claims BNSF failed to protect him from the risk of injury due to shock and vibration.

According to Moore, he suffered serious, painful and permanent injuries to his spine and the discs in his spine which causes pain and mental anguish, medical expenses, loss of wages and fringe benefits and loss of a normal life.

Moore is represented by Steven Groves of St. Louis.

The case has been assigned to Circuit Judge Barbara Crowder.

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