On or about March 1, 2024, the Plaintiff was employed at the Wanderlust and Buffalo Bend construction project in the City of Lewisville, Denton County, Texas. This project involved the replacement of streets, as well as water and wastewater lines within a residential subdivision. The work required the use of specific tools, safety equipment, and procedures to ensure safe working conditions, particularly when performing excavation and trenching activities.
The Plaintiff was working at the job site and was under the direction, supervision, and control of the Defendants. While performing his assigned duties, the trench in which he was working suddenly collapsed, trapping him beneath the earth with no means of escape. The Plaintiff tragically died at the scene as a result.
At all relevant times, the Defendants owed the Plaintiff a duty to provide a safe workplace, to warn of any known or reasonably discoverable hazards, and to furnish appropriate tools, safety equipment, and protective systems necessary to perform the work safely. Defendants breached this duty by failing to provide trench safety measures such as a harness, lifeline, or other protective systems designed to prevent or mitigate the risk of trench collapse. Furthermore, Defendants failed to perform adequate soil analyses, provide necessary safety training, and implement required trench protective systems.
This gross negligence and failure to follow applicable safety standards and procedures directly and proximately caused the fatal injuries sustained by the Plaintiff.

