Joann Jackson filed suit against Conoco Phillips, Kellogg Brown & Root Services Inc., Halliburton Energy Services Inc. and XYZ Insurance Co. on Dec. 3 in Plaquemines Parish District Court. The defendants removed the case to federal court in New Orleans on Dec. 28.
At the time of the incident on Dec. 3, 2009, Jackson was employed by Securitas Security Services as a security agent and assigned to work at the Conoco Phillips Alliance Refinery in Belle Chasse.
According to the lawsuit, Jackson was walking out of her work building towards the parking lot when she stepped and fell in an uncovered piling hole.
Jackson states that the pilings were driven in the area by the defendants in order to construct a new security building at the plant and were previously capped and covered. She claims that the pilings degraded over time and the plastic caps fell off several pilings, allowing holes to form.
The defendants are accused of failing to erect a barrier or barricade to prevent foot traffic through the area and failing to dig-up each of the pilings to install more robust plastic caps over the pilings.
The defendants are also accused of negligence in allowing the accident to occur due to improperly maintaining the piling holes, creating a dangerous and hazardous condition and failing to take the necessary safety precautions to warn people of the danger.
Jackson is seeking damages for physical injuries, mental and physical pain and suffering, physical impairments, disability, medical expenses, lost wages, loss of earning capacity, loss of enjoyment and quality of life, interest and court costs.
She is represented by New Orleans attorney Brett E. Emmanuel.