Court Grants Summary Judgment in Slip-and-Fall Case Under Hills and Ridges Doctrine

A trial court had ruled in favor of the defendants in a slip-and-fall lawsuit arising from an ongoing snowstorm, citing the hills and ridges doctrine. The plaintiff, who fell on accumulated snow and ice near a parking lot curb, failed to present sufficient evidence showing that the conditions had unreasonably obstructed travel. Given the severe winter weather at the time and the plaintiff’s acknowledgment that the area had been cleared but not salted, the court found no basis for liability and granted summary judgment to the defendants.

During an ongoing snowstorm, the plaintiff slipped and fell on snow and/or ice that had accumulated near the curb in a parking lot. The defendants filed motions for summary judgment. The trial court ruled that under the hills and ridges doctrine, the plaintiff must establish the snow and ice accumulated to such a degree as to unreasonably obstruct travel, creating a hazardous condition for pedestrians. 

In reviewing the record, the trial court found that the premises experienced severe winter weather conditions during and after the incident. The record also established that the plaintiff knew the premises had been cleared of snow but had not been salted. The trial court ruled that the plaintiff had “not presented evidence demonstrating snow and ice unreasonably accumulated to such a degree as to unreasonably obstruct travel or an unreasonable time had passed after the end of the storm.” 

As such, the trial court granted the motions for summary judgment. 

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