A woman who claims she was knocked unconscious and robbed at the Granite City Wal-Mart denies that any fault is attributable to her or that a third party is liable for her damages.
Wal-Mart previously argued in its answer to plaintiff Christine Collins’ complaint that if it is found liable, its fault is less than 25 percent of the total fault attributable to the plaintiff. It also argued that a third party defendant is liable for damages.
Collins answered the affirmative defenses on April 12 through attorney Ellen Burford of Burford Law Office in Granite City. She denies all affirmative and additional defenses asserted by defendants Wal-Mart and Christopher Hodges.
Collins filed the complaint Jan. 29 against Wal-Mart Stores Inc. and Hodges Universal Protectin Services, doing business as Allied Universal Security Services.
According to the complaint, Collins claims she was at the Granite City Wal-Mart store located on West Pontoon Road on Aug. 23, 2020. Collins was allegedly entering the store when a male suspect approached her “with great force” and caused her to lose consciousness. The suspect stole Collins’ personal belongings, including her purse, wallet, car keys and other belongings.
She argues that Wal-Mart “knew that the nature of its business, the location of its place of business and from previous experience that it was reasonably foreseeable that one of its customers would be the victim of a criminal attach (sic) while conducting business on its premises.”
Collins alleges Wal-Mart failed to provide adequate security to protect customers from an unreasonable risk of harm, failed to warn her of the attack when it knew it was imminent, failed to contact the local police, allowed a group of hostile and aggressive males to remain on its premises, failed to adequately hire and train qualified security guards and failed to retain a qualified security company.
Allied Universal Security Services was employed by Wal-Mart to field and receive complaints about unsafe conditions. It was also responsible for managing the premises to prevent the existence of unsafe shopping conditions. Collins alleges Allied Universal Security Services owed a duty to provide a reasonably safe store and parking lot.
Collins alleges the defendants failed to provide adequate security to protect customers from an unreasonable risk of harm, failed to warn her of the attack when it knew it was imminent, failed to contact the local police, allowed a group of hostile and aggressive males to remain on its premises, failed to adequately hire and train qualified security guards and failed to retain a qualified security company.
Collins claims that as a result of the attack, she suffered serious and permanent injuries, including emotional anguish and distress.
This article was first published in Madison Record.
