A delivery driver has filed suit against Gateway Regional Medical Center, alleging he sustained injuries to his neck, head, back and shoulder after a leveler collapsed while he was standing on it.

Douglas Luksza Jr. claims he was attempting to deliver a package on behalf of Delivery Logistics to Granite City Illinois Hospital Company doing business as Gateway on Jan. 14 at about 10 a.m. when the incident occurred.

"Doug had backed his cargo van up to one of Gateway's elevated loading docks to complete his delivery and had placed a package on one of the dock's levelers," the suit filed June 8 in Madison County Circuit Court states. "Doug then climbed the stairs to the loading dock platform and proceeded to the leveler where he had placed the package. Upon stepping onto the leveler to retrieve the package, the leveler suddenly and without warning malfunctioned causing Doug to fall to the ground."

In addition to his injuries, Douglas Luksza Jr. suffered great pain and mental anguish, lost income and has been unable to return to his normal life duties, the complaint says.

His wife, Brenda Luksza, claims she lost her husband's love, society, companionship, affection, consortium, support and services.

Gateway negligently caused a defective leveler to exist on its property, allowed a leveler to exist and be used on its property that could fail, failed to adequately inspect and test the leveler to determine its safeness, failed to construct and maintain the leveler to prevent it from causing injuries to Dougals Luksza and failed to warn that the leveler was in a defective condition, according to the complaint.

In their three-count complaint, Douglas Luksza Jr. and his wife are seeking a judgment of more than $150,000, plus costs.

Keith Short and Noel L. Smith Jr. of Hazlett and Short in Shiloh will be representing him.

Madison County Circuit Court case number: 10-L-598.

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