IN THE UNITED STATE DISTRICT COURT 

NORTHERN DISTRICT OF INDIANA 

LAFAYETTE DIVISION 

MYRON MOREHOUSE and 

AMY MOREHOUSE, 

) 

) 

)

 Plaintiff, ) 

)

vs. ) 

)

FLUOR ENTERPRISES, INC., 

ECOA INDUSTRIAL PRODUCTS, INC., and 

ALCOA, INC., 

) 

) 

) 

)

 Defendants. ) 

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 

 Plaintiffs state as follows: 

I. Jurisdiction 

1. The Plaintiffs Myron Morehouse and Amy Morehouse are husband and wife and are 

residents of Indiana. 

2. The Defendant Fluor Enterprises, Inc. (“Fluor”) is a corporation incorporated under 

the laws of California with its principal place of business in Texas. 

3. The Defendant ECOA Industrial Products, Inc. (“ECOA”) is a corporation 

incorporated under the laws of Florida with its principal place of business in Florida. 

4. The Defendant Alcoa, Inc. (“Alcoa”) is a corporation incorporated under the laws of 

Pennsylvania with its principal place of business in New York. 

5. The amount in controversy, without interest and costs, exceeds the sum or value 

specified by 28 U.S.C. § 1332. 

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II. Cause of Action 

6. At all relevant times, Defendant Alcoa contracted with Defendant Fluor to open an 

Aluminum-Lithium Aerospace Plant (“Aerospace Plant Project”) in Lafayette, Indiana. 

7. At all relevant times, Plaintiff Myron Morehouse (“Myron”) was an employee of 

Industrial Contractors, Inc. (“ICI”). 

8. At all relevant times, Myron worked on the Aerospace Plant Project as an employee 

of ICI. 

9. On or around July 8, 2014 while working on the north pit of the Aerospace Plant 

Project at Alcoa, Myron was using a wired control box to operate a scissor lift (“wired control box” 

and “scissor lift”, respectively) that was installed on rails attempting to adjust the stops on the rails. 

10. The wired control box used to operate the scissor lift had four buttons: RIGHT, 

LEFT, DOWN, UP. 

11. There was an inductor on top of the scissor lift and a hoist picking beam was 

attached to the top of the inductor. 

12. Myron pressed one of the buttons on the wired control box to move the scissor lift 

laterally to the west, but while the scissor lift was moving the button on wired control box became 

stuck in the “on” position. 

13. The wired control box did not have a STOP button or an emergency-stop button or 

other emergency-stop mechanism. 

14. As a result of the stuck button and the absence of any stop button or emergency-stop 

mechanism, Myron was not able to stop the scissor lift from moving. 

15. Because the scissor lift did not stop moving laterally, the hoist picking beam 

attached to the top of the inductor collided with the crucible, shearing off the bolts attaching the 

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picking beam to the inductor, causing the picking beam to fall and hit Myron below, causing serious 

injuries. 

16. At all relevant times, the scissor lift and wired control box was owned by Defendant 

Alcoa. 

17. The scissor lift and wired control box was designed by Defendant ECOA. 

18. The scissor lift and wired control box was manufactured by Defendant ECOA. 

19. The scissor lift and wired control box was placed into the stream of commerce by 

Defendant ECOA. 

20. The scissor lift and wired control box was defective and unreasonably dangerous in 

its design and/or manufacturing. 

21. At all relevant times, Defendant Fluor had a duty to maintain a safe workplace and a 

duty to make the facility reasonably safe for business invitees. 

22. At all relevant times, Defendant Alcoa had a duty to maintain a safe workplace and a 

duty to make the facility reasonably safe for business invitees. 

23. Defendant Fluor failed to maintain a safe workplace and failed to keep the facility in 

a reasonably safe condition for business invitees. 

24. Defendant Alcoa failed to maintain a safe workplace and failed to keep the facility in 

a reasonably safe condition for business invitees. 

25. As a direct and proximate result of the careless and negligent acts and omissions of 

the Defendants, each of them, Myron has sustained serious and permanent injuries. He has incurred 

medical expenses and incidental expenses and he will incur additional medical expenses and 

incidental expenses in the future as a result of his injuries. He has lost wages and has suffered 

impairment to his earning capacity as a result of his injuries. He has experienced pain, suffering and 

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mental anguish, and he will continue to experience pain, suffering and mental anguish in the future 

as a result of his injuries. His injuries are permanent in nature and affect his ability to function as a 

whole person. 

26. At all times relevant hereto, the Plaintiff Amy Morehouse was and is the spouse of 

the Plaintiff Myron Morehouse. 

27. As a direct and proximate result of the carelessness and negligence of the 

Defendants, each of them, the Plaintiff Amy Morehouse has sustained damages. She has lost 

income and incurred incidental and miscellaneous expenses as a result of the injuries to her husband 

and she may lose more income and incur incidental and miscellaneous expenses in the future as a 

result. She has lost the value of his services and consortium, and she may lose the value of some of 

his services and consortium in the future. 

WHEREFORE, the Plaintiffs, Myron and Amy Morehouse pray for damages against the 

Defendants in an amount which will fully and fairly compensate him for the damages sustained, for 

costs of this action, for pre-judgment interest and for all just and proper relief in the premises. 

III. Demand for Jury Trial 

 Plaintiffs request a trial by jury. 

 Respectfully submitted, 

 

 ______________________________________

 Robert W. Johnson, Attorney No. 17391-49 

 JOHNSON JENSEN LLP 

 One Indiana Square 

 Suite 1640 

 Indianapolis, IN 46204 

 rjohnson@johnsonjensen.com

 317.269.7799 tel 

 317.269.7784 fax 

 Attorney for Plaintiffs 

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