MADISON - ST. CLAIR RECORD

The relative of a recently deceased woman claims a truck driver caused the woman's death when he struck her as she walked down the street.

Kathy Broyles filed a lawsuit Sept. 22 in Madison County Circuit Court against Jason S. Pieper and Liquid Transport Corp.

In her complaint, Kathy Broyles alleges Brandy S. Broyles was walking west on W. Chain of Rocks Road in Chouteau Township on Aug. 25 when Pieper, who owned a 2006 Kenworth Motor T600 semi-tractor and operated it for defendant LTC, struck her as he drove north on Dial Drive.

"Brandy S. Broyles then and there sustained severe injuries that caused her to have internal bleeding and punctures to both lungs which ultimately caused the death of Brandy S. Broyles," the suit states.

Before her death, Brandy S. Broyles endured severe pain and suffering, lost her earnings, incurred medical costs, sustained a physical disability and lost her enjoyment of life, according to the complaint.

At the time of her death, Brady S. Broyles had two minor sons -- Keaton Boyles and Brandon Romeo, the suit states.

Because of Brandy S. Broyles's death, her family has incurred medical and funeral expenses, the suit states.

Kathy Broyles blames Pieper for causing the collision, saying he negligently failed to control and stop his truck to avoid the collision, failed to sound his horn to warn of his approach, failed to keep a proper lookout for pedestrians and drove the truck too fast.

She also names LTC as a defendant, alleging the company failed to provide Pieper with adequate equipment, failed to equip the truck with adequate warning devices, failed to prevent Pieper from driving the vehicle too quickly, failed to install proper traffic signals to warn pedestrians of the truck's approach and failed to install proper devices to control Pieper's actions.

In addition, the company was negligent in its hiring of Pieper and in failing to train employees to ensure the safety of others, according to the complaint.

In her six-count complaint, Kathy Broyles seeks a judgment of more than $300,000, plus costs and other relief the court deems just.

Michael R. Bilbrey, Michael V. Oltmann and James R. Stever of the Law Offices of Michael R. Bilbrey will be representing her.

Madison County Circuit Court case number: 11-L-957.