RALEIGH, N.C. (WNCN) – The parents of Hailey Brooks, the 11-year-old dancer killed in November’s Raleigh Christmas Parade, have filed a civil lawsuit against the float driver who struck her, as well as others involved in the deadly incident, CBS 17 learned Tuesday.

In the 56-page lawsuit, Hailey’s parents, Trey and April Brooks, said their daughter’s death “would have been prevented if basic, reasonable, and well-known safety protocols had been adopted and enforced.”

It also said, “This action is brought to ensure that those responsible for Hailey’s death are held accountable and to ensure that no other child or person is hurt or killed by the recklessness of those entrusted with and responsible for the safety of the children and attendees at this Raleigh tradition.”

The filed lawsuit names the defendants as driver Landen Glass, C.C. & Co. Dance Complex, Greater Raleigh Merchants Association, Shop Local Raleigh and D&L Floats.

The law firm of Miller, Monroe and Plyler is representing the family.

CBS 17 previously reported the Raleigh Police Department’s preliminary investigation indicated that at 10:14 a.m. on Nov. 19, the driver of a vehicle in the parade, later confirmed as Glass, lost control near the intersection of Hillsborough Street at Boylan Avenue. The vehicle then traveled at a low rate of speed, striking an 11-year-old girl, later confirmed as Hailey.

She was taken away in an ambulance after first responders rushed to help her on the scene, CBS 17 previously reported. She later died of her injuries.

In the suit, Hailey’s parents note that Glass has been cited for more than 20 traffic violations since 2021, including five for failure to have his vehicles inspected. He is also said to have transported 16 or more passengers in the parade without a commercial driver’s license.

According to the lawsuit’s claims, Glass had arrived in Raleigh sometime after 1 a.m. and had less than five hours of sleep the morning of the parade. The suit also noted that Glass had been carrying an illegal handgun in the parade.

Hailey’s parents also detailed Glass’ vehicle history in the lawsuit.

It said that Glass “errantly put power steering fluid in the brake fluid reservoir” and “did not hire an ASE-certified mechanic to flush the power steering fluid from the truck’s braking system.”

The Brooks noted that he tried to flush the fluid himself and the Brooks said they believe contaminants remained in the braking system on the day of the Christmas parade.

Additionally, the lift of Glass’ truck was approximately seven inches, the suit says, resulting in the emergency brake line being terminated.

“The emergency brake cable could be seen disconnected and dangling beneath the driver’s side door of the truck,” the suit reads. “When Defendant Glass was interviewed after the parade, he admitted that he knew the emergency brake was not functional prior to and at the time of the parade. Defendant Glasses’ operation of the truck in the parade without a braking system adequate to control the movement of and to stop such vehicle or vehicles was illegal.”

Further, Trey and April Brooks are suing CC & Co. after they say the dance company participated in the parade to promote and market its studio. In doing so, the suit claims the company hired Glass, a former student, to save money on pulling its float and failed to go over safety guidelines with dancer families before the Christmas parade.

The details against CC & Co. span many pages.

As for Greater Raleigh Merchants Association, the Brooks’ are suing for negligence, gross negligence and wrongful death. They detail how it had a duty to be sure all things in the parade operated in a safe manner, had policies in place for health and safety and completed thorough inspections, among other things.

Trey and April Brooks are seeking $25,000 or more per claim. They have filed 10 in total.

Chloe Rafferty, Kathryn Hubbard and Hayley Fixler contributed to this article.