MADISON - ST. CLAIR RECORD

The mother of a minor child claims her son sustained injuries to his right leg after falling on a hole in the playground.

Sororial Cotton filed a lawsuit Feb. 22 in St. Clair County Circuit Court against Belleville Public School District No. 118, Jim Slater and Donna Altemeier.

Cotton claims her son, referred to only as D.M. throughout the complaint, was participating in recess at Roosevelt Grade School on Feb. 22, 2010, when his foot and legs got caught in a crack, causing him to immediately fall to the pavement.

"D.M. then and there required medical care and was taken to an indoor location within Roosevelt Grade School, at which time Altemeier maneuvered, jostled and manipulated Plaintiff's foot/feet and legs such that parts of D.M.'s body were injured, including but not limited to his right leg," the suit states.

In addition to his injuries, D.M. became sick, sore and lame; suffered great physical pain and mental anguish; and was forced to undergo medical treatment, the complaint says.

Cotton claims she had to incur medical costs.

In her complaint, Cotton alleges negligence and willful and wanton conduct against the school district, saying it failed to repair the crack or hole before the incident, failed to warn D.M. of the crack or hole and failed to restrict student access to the area where the hole was located. In addition, the school negligently failed to inspect the recess area, failed to provide adequate supervision, failed to establish policies for proper supervision, failed to provide reasonable first-aid to D.M. and failed to immobilize D.M. after his fall, according to the complaint.

Jim Slater, director of buildings and grounds for the school district, is also named as a defendant for his alleged failure to repair the hole, to warn D.M. of the existence of the hole, to restrict student access to the area of the hole and to reasonably inspect the recess area, the suit states.

Donna Altemeier, an administrative assistant at the school, negligently failed to provide reasonable first aid to D.M., failed to immobilize D.M. after his fall and maneuvered D.M.'s feet so that he was caused to sustain injury, the complaint says.

Cotton seeks a judgment of more than $300,000, plus other relief the court deems just.

Rhonda D. Fiss of The Law Office of Rhonda D. Fiss in Belleville will be representing her.

St. Clair County Circuit Court case number: 11-L-87.