ELECTRONICALLY FILED - 2023 Mar 14 11:08 AM - RICHLAND - COMMON PLEAS - CASE#2023CP4001358

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

)
COUNTY OF RICHLAND )
)
Eric Dreher, )
)
Plaintiffs, )
) COMPLAINT
Vs. ) (Jury Trial Requested)
)
Sophia Alexander, Individually and as )
Agent of City of Columbia, COMET )
Central Midlands Transit and Central )
Midlands Regional Authority, and City )
Of Columbia, COMET Central Midlands )
Transit and Central Midlands Regional )
Authority, )
)
Defendants. )
)
____________________________________)

Eric Dreher, the Plaintiff in this matter does make the following claims:

1. The Plaintiff, Eric Dreher (hereinafter referred to as “Plaintiff Dreher”) is both a

citizen and resident of Richland County, South Carolina.

3. The Defendant, Sophia Alexander (hereinafter referred to as Defendant Alexander)

is a citizen and resident of Richland County, South Carolina and was employed by the Defendant,

City of Columbia, COMET Central Midlands Transit and Central Midlands Regional Authority,

at the time of this incident.

4. The Defendant, City of Columbia (hereinafter Defendant Columbia) is a

corporation licensed and conducting business in the State of South Carolina.

4. The Defendant, Central Midlands Regional Authority (hereinafter Defendant

Central) is a corporation licensed and conducting business in the State of South Carolina.

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 ELECTRONICALLY FILED - 2023 Mar 14 11:08 AM - RICHLAND - COMMON PLEAS - CASE#2023CP4001358
5. The Defendant, COMET Central Midlands Transit (hereinafter Defendant

COMET) is a corporation licensed and conducting business in the State of South Carolina.

6. The accident giving rise to this litigation occurred in Richland County, South

Carolina.

7. Venue is proper pursuant to §15-7-30 of the South Carolina Code of Laws

Amended.

8. The Court has subject matter jurisdiction over this matter and in personam

jurisdiction over the parties.

FACTS

9. At all times relevant herein Defendants’ employee, Defendant Alexander was

driving a city bus, while acting as agent, servant and employee and in the course and scope of her

employment with Defendants.

10. On or about July 25, 2022, Defendant Alexander failed to properly park the city bus

on Surrey Street in Columbia, South Carolina.

11. The Defendant Alexander exited the bus to inspect a warning light without properly

parking the bus.

12. At approximately the same time, Plaintiff Dreher was a passenger on the city bus

when it began rolling backwards and down an embankment and collided with a tree.

13. This collision caused serious and permanent bodily injuries to the Plaintiff.

14. The Defendant’s had a duty to ensure that their drivers had sufficient training to

prevent harm to the public.

15. That the Defendant’s had a duty to the Plaintiff to train drivers like Defendant

Alexander of the dangers of not properly placing a city bus in park.

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16. That the Defendants had a duty to carefully select qualified truck drivers to prevent

harm to the public.

17. That the Defendants had a duty to constantly evaluate the safety of their drivers to

present harm to the public.

18. That the Defendants was not allowed to endanger the public.

19. That the Defendants’ drivers had a duty to follow traffic laws to prevent harm to

the public.

FOR A FIRST CAUSE OF ACTION AS TO ALLWASTE

(Negligence, Gross Negligence, and Recklessness)

20. Plaintiffs re-allege the allegations of all paragraphs above as if restated verbatim.

21. The Plaintiffs will show that at the times and places above mentioned that

Defendants’ driver, while acting as agent, servant, employee and at the direction of Defendants was

willful, wanton, careless, negligent, grossly negligent, and reckless in the following particulars:

a. In operating his vehicle at an improper speed;

b. In following other vehicles too closely;

c. In failing to keep a proper lookout;

d. In failing to see or observe things which a reasonable person should see;

e. In failing to maintain reasonable vigilance and anticipate others use of the

roadway;

f. In failing to appropriately apply his brakes or otherwise stop or move his

vehicle;

g. In failing to sound his horn;

h. In driving his tractor trailer truck in a careless and heedless fashion on the

roadway so as to endanger other persons or property;

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 ELECTRONICALLY FILED - 2023 Mar 14 11:08 AM - RICHLAND - COMMON PLEAS - CASE#2023CP4001358
i. In failing to abide by the proper rules and regulations concerning

appropriate rest;

j. In driving under an impaired and fatigued condition;

k. In operating a vehicle without adequate lighting or reflectors;

l. In failing to use the degree of care and skill required by a tractor trailer

driver under the same or similar circumstances;

m. In such other and further ways as discovery may reveal.

22. That the above acts and omissions were the direct and proximate cause of the injuries

and damages sustained by the Plaintiffs herein, the said acts and omissions being in violation of the

common and statutory law of the state of South Carolina and such other law as may apply.

FOR A SECOND CAUSE OF ACTION AS TO ALL DEFENDANTS

(Negligent Hiring)

23. Plaintiffs re-allege the allegations of all paragraphs above as if restated verbatim.

24. The Defendants owed a duty to the Plaintiffs and others to hire only personnel who

were appropriate to operate commercial motor vehicles and not to hire personnel who placed the

Plaintiffs and others at a risk of bodily injury or death.

25. Defendants breached that duty continually by hiring personnel who committed the

acts described in this Complaint and others, and in fact encouraging the same, and the Defendants

had knowledge that these persons committed wrongful prior conduct but failed to remedy the

situation.

26. As a result of Defendants’ conduct, the Plaintiffs are entitled to actual and punitive

damages for physical injury, pain and suffering, mental anguish, loss of human dignity and other

matters caused by the same, in an amount to be determined at the trial of this action.

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FOR A THIRD CAUSE OF ACTION AS TO DEFENDANTS
(Negligent Supervision)

27. Plaintiffs re-allege the allegations of all paragraphs above as if restated verbatim.

28. The Defendants owed a duty to the Plaintiffs and others to supervise its personnel

and determine if these persons were appropriate to operate commercial motor vehicles and not to

allow these personnel to place the Plaintiffs and others at a risk of bodily injury or death.

29. The Defendants breached that duty by failing to supervise the personnel who

committed the acts described in this Complaint and others, and the Defendant had knowledge that

this person was likely to commit and/or did commit wrongful conduct but failed to remediate the

situation.

30. As a result of the Defendants’ conduct, the Plaintiffs are entitled to actual and

punitive damages for physical injury, pain and suffering, mental anguish, loss of human dignity

and other matters caused by the same, in an amount to be determined at the trial of this action.

FOR A FOURTH CAUSE OF ACTION AS TO DEFENDANTS

(Negligent Retention)

31. Plaintiff re-alleges the allegations of all paragraphs above as if restated verbatim.

32. The Defendants owed a duty to the Plaintiff and others to investigate the wrongful

and unacceptable conduct of its personnel and take appropriate action.

33. Defendants breached that duty by failing to undertake any appropriate

investigation, discharge, remedial training or reassignment.

34. As a result of the Defendants’ conduct, the Plaintiff is entitled to actual and punitive

damages for physical injury, pain and suffering, mental anguish, loss of human dignity and other

matters caused by the same, in an amount to be determined at the trial of this action.

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35. As a direct and proximate result of the wrongful acts and omissions set forth above

as committed by the Defendants, the Plaintiff has suffered:

a. personal injury;
b. pain and suffering;
c. mental anguish;
d. loss of enjoyment of life;
e. medical expenses
f. lost wages;
g. loss of society/companionship;
h. permanent impairment;

for which the Plaintiff is entitled to recover an amount of actual, punitive, special and

consequential damages to be determined by a jury at the trial of this action.

WHEREFORE, Plaintiffs respectfully pray for judgment against the Defendants for all

actual damages, special damages, consequential damages, and punitive damages in an amount to

be determined by the jury at the trial of this action, the costs and disbursements of this action and

for such other and further relief as this court deems just and proper.

BURRISS AND RIDGEWAY

s/E. Wayne Ridgeway, Jr.

SC Bar No 71194
Attorney for Plaintiff
820 Gracern Road
Columbia, SC 29210
Phone: 803-451-4000
Fax: 803-227-0384
[email protected]
Columbia, South Carolina
March 14, 2023

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 ELECTRONICALLY FILED - 2023 Mar 14 11:08 AM - RICHLAND - COMMON PLEAS - CASE#2023CP4001358
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
)
COUNTY OF RICHLAND )
)
Eric Dreher, )
)
Plaintiffs, )
) SUMMONS
Vs. )
)
Sophia Alexander, Individually and as )
Agent of City of Columbia, COMET )
Central Midlands Transit and Central )
Midlands Regional Authority, and City )
Of Columbia, COMET Central Midlands )
Transit and Central Midlands Regional )
Authority, )
)
Defendants. )
)
____________________________________)

TO: THE DEFENDANTS NAMED ABOVE:

YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, a

copy of which is herewith served upon you, and to serve a copy of your Answer upon the subscriber

at Burriss & Ridgeway, located at 820 Gracern Road, South Carolina 29210, within thirty (30) days

after service hereof, exclusive of the day of such service. If you fail to answer the Complaint within

such time aforementioned, the Plaintiff will apply to the Court for the relief demanded in the

Complaint and Judgment by default will be rendered against you for the relief demanded in the

Complaint and an Order of Default will render against you for the relief so demanded in the

Complaint.

Signature Page to Follow

 ELECTRONICALLY FILED - 2023 Mar 14 11:08 AM - RICHLAND - COMMON PLEAS - CASE#2023CP4001358
BURRISS AND RIDGEWAY

s/E. Wayne Ridgeway, Jr.

SC Bar No 71194
Attorney for Plaintiff
820 Gracern Road
Columbia, SC 29210
Phone: 803-451-4000
Fax: 803-227-0384
[email protected]
Columbia, South Carolina
March 14, 2023