A Granite City mail carrier seeks summary judgment 18 months after filing a trip and fall suit, arguing that the home owners have failed to respond or enter an appearance.
Plaintiff Lavatrice Morgan filed a motion for default judgment against defendants William and Morgan Campbell on Dec. 11 through attorney Thomas Maag of the Maag Law Firm LLC in Wood River.
Morgan argues that she filed her complaint in May 2016 and served the defendants in June 2016.
Approximately 18 months have passed and the defendants have failed to plead, appear or respond to the suit.
Morgan requests the court enter judgment in her favor for $100,000, plus court costs and any other relief the court deems just.
In Morgan’s complaint, she alleges she was working as a letter carrier at the Granite City Post Office on March 28, 2016, when she fell while delivering mail.
She claims she was delivering mail at the defendants’ home on Poplar Street in Granite City when she stepped in a hole in the defendants’ yard and twisted to the right. As a result, she fractured her left ankle, the suit states.
William Campbell owns the property while Morgan Campbell resides at the property.
Morgan alleges it was the defendants’ duty to maintain the property. She also alleges they had a duty to use reasonable care for the safety of others.
She claims the defendants failed to warn others of the hole, fill in the hole or repair the hole on the property.
Madison County Circuit Court case number 16-L-734