The sister of Lukisha Thomas has filed a complaint against the man driving the SUV that struck and killed the 29-year-old mother while she was walking on the sidewalk earlier this year.

A summons filed in September by Mt. Pleasant attorney Ladson Howell Jr. lists Maria Saxon, Thomas' sister and the personal representative of Thomas' estate, as the plaintiff, and Thomas Woodruff Jr. as the defendant.

Thomas was walking on the sidewalk of York Street on March 30 along with her boyfriend, Ray Charles Wooden Jr. and her 2-year-old son when a 2006 Jeep driven by Woodruff left the roadway and struck them. Thomas later died during surgery. Her son was treated and released that day from a hospital, while Wooden was hospitalized for several weeks.

Woodruff, an Aiken attorney, was charged with careless driving.

The complaint, which demands a jury trial, lists several “factual allegations,” among them that Woodruff killed Thomas in front of her child, that he has made no apology to Saxon or any other member of Thomas' family, and that he “refused” to appear at a hearing held on May 6 “despite knowing that Ms. Thomas's surviving family wished for him to do so.”

The complaint lists negligence as the first cause of action and contends that Woodruff was “negligent, grossly negligent, negligent per se, careless and reckless” in at least one of several particulars, including failing to keep a proper lookout, failing to properly equip his motor vehicle with adequate and safe brakes, operating the vehicle at a speed “which was excessive under the circumstances,” and failing to take any evasive action to keep from striking Thomas, Wooden and her child.

Saxon is seeking compensation for medical expenses; pain and suffering for the period proceeding death; fright, grief, mental distress and mental anguish; funeral expenses; and exemplary damages.

The complaint lists wrongful death as the second cause of action and says that as a result of Woodruff's “negligence, reckless, willful and wanton acts and omissions,” Saxon is entitled to compensation for pecuniary loss, mental shock and suffering, wounded feelings, loss of companionship and loss of the ability to earn money for the support, maintenance, care and protection of her children.

The document lists survival as the third cause of action under Section 15-5-90 of the 1976 Code of Laws of South Carolina, which dictates survival of right of action.

The summons states that Woodruff had 30 days from the service of the complaint to answer it. The summons and complaint were filed with the Aiken County Clerk of Court on Sept. 20, and they remain the only filings in the case as of Monday afternoon.

Woodruff could not comment on pending litigation. He is being represented by Aiken attorney Rob Braithwaite.

Teddy Kulmala covers the crime and courts beat for the Aiken Standard and has been with the newspaper since August 2012.