Slip and Fall on Snow or Ice?

Property Owners and Businesses Have a Duty to Remove Snow and Ice

With the first hints of snow in the weather forecast, it is a good time to review liability for slip and fall injuries under Pennsylvania law.  Unfortunately, falls on ice or snow are common in winter and can result in serious injury. Generally speaking, property owners in Pennsylvania have a duty to remove snow and ice from their sidewalks and walkways in a reasonable amount of time after an accumulation. Pennsylvania law does not, however, require a property owner to keep sidewalks and walkways free of snow and ice at all times. Given the unpredictable weather in Northeastern Pennsylvania, this would be an impossible standard to meet. Instead, courts have developed the "Hills and Ridges Doctrine" to evaluate slip and fall claims due to wintery conditions.

The "Hills and Ridges Doctrine" establishes criteria for courts to look at when evaluating the liability of a property owner for injuries in a slip and fall on snow or ice. Under the doctrine, there must be "naturally created dangerous conditions in the form of hills, ridges or elevations in the snow or ice" which are allowed to remain for an unreasonable amount of time after a snowfall. Rinaldi v. Levine, 176 A.2d 623 (Pa. 1962). The hills, ridges or elevations must be of such size and character as to reasonably obstruct travel and create a dangerous condition. Gilligan v. Villanova University, 584 A.2d 1005 (Pa. Super. 1991).  The most critical element requires that the property owner had either actual or constructive knowledge of the dangerous condition caused by the snow or ice. Id. Finally, it must also be shown that the dangerous condition, and not some other factor, actually caused the fall. Id.

Falls caused by localized patches of ice or icy conditions caused by a property owners neglect may be treated differently under the law. If you have any questions about the "Hills and Ridges Doctrine" or premise liability law in Pennsylvania, call 570-718-4900 today.