Sam Bass Direct

2022 - 2023 (10th grade ): State of Texoma v. Bon E Barrow

Hello, could you please introduce yourself to the court?

Hello, my name is Sam Bass. I am a professional engineer, and I specialize in investigating structural failures. Essentially, my job is to examine why structures failed to ensure that it doesn’t happen again.

What experience do you have as a structural engineer?

I am currently the president of BSI, or Bass Structural Investigations. Previously, I was a building inspector with the Texoma Buildings Department, or TBD. I joined in 2014, straight out of college, where I graduated as valedictorian. In 2020, I was promoted to senior building inspector, which was my title when I went to investigate the scaffolding collapse of Fox Avenue. I have consulted on numerous cases with TBD, which includes testifying in court. This is the second case I have consulted on with BSI.

What was the first case you consulted on?

My first case with BSI was over a one-story building where an exterior wall collapsed and destroyed everything inside it. After my investigation, I concluded that the foundation hadn’t set long enough, causing the incident. The building’s insurance company brought me on the case, and I was deposed by the lawyers of the building’s contractor a few days later. The contractor eventually settled, and the insurance company was thrilled. They said they would call me again for any other consulting they might need.

What is your approach to investigating a scene?

I analyze the scene and examine the evidence I find in order to reach a plausible conclusion. I also sketch out everything I observe while it is fresh in my mind.

How do you draw conclusions on a case, based off of your investigations of the scene?

As part of my analysis, I employ my observations and make logical deductions, occasionally accompanied by laboratory analysis of things like the strength of concrete, the corrosion of steel, and errors in construction, which help me determine what went wrong. It is a very logical and straight-forward process, attempting to connect the puzzle pieces that is the evidence in order to create the big picture.

Moving on, when where you brought onto today’s case?

On March 12, 2022, I received a phone call from one of my TBD supervisors just after 9 pm. They explained that a speeding sports car had crashed into some scaffolding, causing the death of a pedestrian. I quickly walked from my apartment to the nearby scene on Fox Avenue.

What did you see once arriving on Fox Avenue?

It was a huge mess, there were lots of police lights flashing, and yellow caution tape sealing off the streets. I flashed my TBD credentials and began examining the scene. Luckily, I was already familiar with the construction of the scaffolding.

Why were you familiar with the construction of the scaffolding?

I was the TBD representative that had approved the permit for the scaffolding’s construction about a week earlier. In order for the permit to be approved, the contractor had to submit renderings of the exact scaffolding set-up they were going to use, so when I went to investigate that night, I knew what I was looking at.

What did you observe about the scaffolding when you went to observe it?

The scaffolding units all matched up with the renderings submitted by the contractor, and the set-up, or what was left of it, fit with what the contractor had planned to do. I concluded that the scaffolding itself had not posed any danger. The bricks found on the sedan, however, were a different story altogether.

What was the issue with the bricks?

It was one of three cubes of bricks found in that area that night. A cube of bricks is made up of 540 individual bricks, which adds up to a considerable amount of weight. These bricks had been left overnight on the top levels of the scaffolding, which is extremely dangerous, and is a clear violation of Texoma Building Code.

And were the bricks the cause of the scaffolding collapse, in your expert opinion?

Surprisingly, no, the bricks did not cause the scaffolding to collapse. One of the cubes of bricks had fallen along with the scaffolding, but was very well intact, which suggested to me that the bricks had fallen with the scaffolding, and had not caused the scaffolding to collapse.

What did you notice about the black sedan sportscar upon inspecting it?

Despite being crushed by those bricks, the sedan still had power, as was evidence by the many interior lights that were on inside. However, the headlights were not on, although it was late at night. I also noticed that there were scratch marks on the side of the sedan, which stood out to me.

What did you conclude after inspecting the black sedan?

The scratch marks on the sedan indicated to me that the sedan had crashed into the scaffolding, and not the other way around. The fact that the headlights were not on pointed towards the recklessness of the driver. Furthermore, I overheard some officers talking about how the car radio had been blaring when they arrived on the scene, which again pointed towards a careless driver.

What else did you investigate while on the scene?

There were a few things that I noticed regarding the sedan. First, there were no skid marks, meaning the driver hadn’t started to brake even after jumping the curb and hitting the scaffolding. The driver, who I now know is Kinton Cane, must have been incapacitated, drunk, or plain reckless to have jumped a curb and crashed into the scaffolding without even attempting to brake.

What else did you learn about the sedan?

I was informed by the police officers that Cane had been speeding all the way up until they crashed into the scaffolding. In fact, there was a barricade between the street and the scaffolding, and it hadn’t been touched by the sedan.

What was significant about the fact that this barricade hadn’t been touched?

The only way the sedan could have avoided the barricade was by jerking sharply into the scaffolding. That and the speeding only added to how reckless the sedan had been, and supported my theory that the sedan had caused this tragedy.

Based on your investigation of the scene of Tee Dealy’s death, how did you begin to formulate your conclusion of the case?

I started by going over the significant pieces of evidence. First, the scaffolding had been properly constructed, and the construction itself was not the cause of the crash. The intact cube of bricks made it clear that the bricks hadn’t caused the scaffolding to collapse, and it had to have been caused by an outside force.

What other pieces of evidence did you consider?

The scratches on the sedan show that it crashed into the scaffolding, causing it and the bricks to fall, which unfortunately landed on Tee Dealy. The turned off headlights, the radio blaring, the speeding, and the sharp turn to avoid the barricade… they all point to the same conclusion.

What is your final conclusion on this case?

In my expert opinion, all the evidence analyzed creates one clear picture: Kinton Cane’s reckless driving led to Tee Dealy’s death. The black sedan sportscar was being driven recklessly, erratically, and dangerously by Kinton Cane. Therefore, Kinton Cane crashed into the scaffolding. Kinton Cane caused the cube of bricks to fall. Kinton Cane caused the death of Tee Dealy.