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LOUIS
TWENTY-SECOND JUDICIAL CIRCUIT
STATE OF MISSOURI
REGINALD BUSH,
Plaintiff,
vs.
Case No.
Division:
Plaintiff Reginald Bush is a resident and citizen of California. Bush played for
the USC Trojans football team from 2003 to 2005 where he enjoyed one of the greatest
collegiate athletic careers of all time. The second overall pick of the New Orleans Saints in the
2006 NFL draft, Bush was part of the Saints team that won the franchises first Super Bowl in
2010. In 2011, Mr. Bush was traded to the Miami Dolphins where he played two seasons before
signing with the Detroit Lions on March 13, 2013. In 2015, Reggie signed with the San
1622-CC00013
years in the league, amassing over 9,000 total yards from scrimmage and 57 career touchdowns.
2.
(RSA) is a body politic and corporate and a public instrumentality duly organized and existing
under the laws of the State of Missouri. The RSA constructed, operates, leases, controls, owns,
possesses, and maintains The Edward Jones Dome (the Dome).
3.
body corporate and politic of the State of Missouri. The CVC maintains, operates, controls,
possesses and manages the Dome.
4.
5.
Venue is proper in this Court pursuant to MO. REV. STAT. 508.010 because
On November 1, 2015, the San Francisco 49ers played the St. Louis Rams at the
At that time, the turf playing field at the Dome was surrounded by a slippery
controlled, and possessed the Dome, including the playing surface and surrounding concrete
surface.
9.
Reggie Bush was playing in the game as a running back for the San Francisco
49ers.
Francisco 49ers. Bush has been an explosive threat as a runner, receiver, and returner in his 10
With approximately 5:30 left in the first quarter, Mr. Bush ran out of bounds
After the play had concluded, and while trying to slow down out-of-bounds, Mr.
Bushs momentum carried him from the turf to the concrete surface.
12.
Mr. Bush slipped on the concrete surface and injured his left knee, ending his
13.
One week prior to Mr. Bushs injury, on October 25, 2015, Josh McCown,
season.
quarterback for the Cleveland Browns, injured his shoulder after slipping on the same concrete
surface.
14.
Two weeks after Mr. Bushs injury, Defendants covered the concrete surface with
16.
Defendants.
17.
Defendants were in control and possession of the Dome, including the playing
Defendants owed a duty to the general public and specifically those invited on the
field, including, but not limited to, players, coaches, trainers, media, youth football players,
cheerleaders, fans, and referees to remove or warn of dangerous conditions in the Dome and to
maintain the Dome, including the playing surface and surrounding areas, in a reasonably safe
condition.
10.
dangerous condition to exist at the Dome, creating an unreasonable risk of injury to those invited
on the field and surrounding surfaces, including Mr. Bush. Specifically, the turf playing field
was surrounded by a slippery concrete surface. This abrupt change in surface was not reasonably
safe.
20.
As described above, Mr. Bush slipped and fell on the slippery concrete surface,
Defendants knew or by using ordinary care could have known of the dangerous
condition. Indeed, just one week prior, another NFL player was injured by the same dangerous
condition.
22.
condition.
23.
damages in the form of lost wages, medical expenses, loss of future earnings, and pain and
suffering.
24.
the safety of Mr. Bush and others, thereby justifying an award of punitive damages to punish
Defendants and to deter Defendants and others from like conduct.
WHEREFORE, Plaintiff Reginald Bush prays for judgment against Defendants in a fair
and reasonable amount in excess of twenty-five thousand dollars ($25,000.00), for punitive
damages, his costs herein incurred, and for such other and further relief as may be just and
proper.
19.
25.
26.
Defendants owed Mr. Bush and the general public a duty of reasonable care.
27.
Defendants breached the duty owed to Mr. Bush by one or more of the following
damages in the form of lost wages, medical expenses, loss of future earnings, and pain and
suffering.
29.
the safety of Mr. Bush and others, thereby justifying an award of punitive damages to punish
Defendants and to deter Defendants and others from like conduct.
WHEREFORE, Plaintiff Reginald Bush prays for judgment against Defendants in a fair
and reasonable amount in excess of twenty-five thousand dollars ($25,000.00), for punitive
damages, his costs herein incurred, and for such other and further relief as may be just and
proper.
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COUNT II NEGLIGENCE
(ALL DEFENDANTS)
Respectfully Submitted,