A Utah man sued Gwyneth Paltrow for at least $3.1 million on Tuesday, claiming that the “Iron Man” and “Shakespeare in Love” star crashed into him on a Deer Valley bunny slope in 2016, causing serious injuries.

“Gwyneth Paltrow knew it was wrong to ski out of control too fast for her ability and distracted, but she did it anyway,” wrote Robert Sykes of Salt Lake City's Sykes McAllister on behalf of optometrist Terry Sanderson.

“Gwyneth Paltrow knew it was wrong to slam into Dr. Sanderson's back, knocking him down, landing on top of him, knocking him out and then leave the scene of the ski crash she caused, but she did it anyway,” Sykes continued in the 9-page complaint filed in the Third Judicial District Court in Summit County, Utah.

Paltrow is represented by Stephen Owens of Epperson & Owens in Salt Lake City, who referred inquiries to Paltrow's publicist, Heather Wilson. In an emailed statement, Wilson said, “This lawsuit is completely without merit. Anyone who reads the facts will realize that.”

One threshold question: If Sanderson was knocked out by the impact, how did he know it was Paltrow who hit him?

Sykes in an interview said his client was skiing with an acquaintance who “was 30 feet away, he witnessed the whole thing.”

But Paltrow has at least one witness too, ski instructor Eric Christiansen, who was allegedly skiing with the actress and her group on the Bandana trial, a beginner run.

He's named in the suit along with unidentified Deer Valley employees and the resort itself.

According to the complaint, immediately after the crash Christiansen “screamed at plaintiff 'What did you do?!'” (A remark which suggests he thought the accident was Sanderson's fault).

The instructor also allegedly failed to call the ski patrol or other emergency responders, which Sanderson says was a breach of duty and caused negligent infliction of emotional distress.

Moreover, Sanderson alleges that the resort tried to cover up Paltrow's culpability.

“Shortly after the crash, plaintiff asked Deer Valley employees what had happened, what records Deer Valley had, and what Deer Valley was doing to investigate the crash. Deer Valley produced false information to plaintiff indicating that Paltrow did not cause the ski crash that injured plaintiff.”

But Sykes stressed that his client was the downhill skier. In almost all circumstances, it's the responsibility of the uphill skier to avoid those below them.

While accidental slope-side collisions are not uncommon, a key factor in liability is whether the skier who caused the accident was negligent or reckless.

Sanderson says Paltrow was.

“Defendant Gwyneth Paltrow had a duty to ski safely, but she negligently breached that duty by skiing unsafely, striking a downhill skier, plaintiff, in the back, knocking him down, landing on top of him, and causing him to suffer a concussion, brain injury and 4 broken ribs,” Sykes wrote.

He seemed particularly dismayed that Paltrow then allegedly skied away. “It's a sad thing. Basic human kindness requires that you stop,” he said.

A personal injury, med mal, product liability and civil rights specialist, Sykes said that Paltrow's celebrity status won't affect his approach to litigating the case (though I find it hard to believe her deep pockets didn't affect his willingness to bring it). “That she's famous doesn't make any difference to us,” he said. “We just want justice for our client.”

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