CHARLESTON - A former employee is suing Thomas Memorial Hospital after she claims she was injured on the job.

On Aug. 13, 2012, Jackie Simmons began her employment at the hospital as a housekeeper, according to a complaint filed June 18 in Kanawha Circuit Court.

Simmons claims on Nov. 6, she was emptying garbage into a dumpster when the lid of the dumpster came down, hitting her upper extremity and causing injuries.

The defendant had actual knowledge of the existence of the unsafe working condition and of the high degree of risk and strong probability of serious injury or death, according to the suit.

Simmons claims the defendant allowed the specific unsafe working condition to exist in the workplace. The unsafe working condition was a violation of a state or federal safety statute, rule or regulation.

As a direct and proximate result of the defendant's negligence, Simmons endured great pain and suffering in mind and body; incurred expenses for medical treatment; and suffered a loss of income and sustained an impairment of earning capacity, according to the suit.

Simmons is seeking compensatory damages with pre- and post-judgment interest. She is being represented by Samuel F. Hanna.

The case is assigned to Circuit Judge Charles E. King.

Kanawha Circuit Court case number: 15-C-1236

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