Pennsylvania Commonwealth Court notes that walking across undeveloped land carries an inherent risk of falling over depressions.

This matter concerns the plaintiff’s trip and fall on a snow-covered grassy area between two parking lots at the Westmoreland County Airport. The plaintiff tripped over a concealed five-inch-deep depression while cutting across the grassy area to get to her car, instead of taking a longer path across a snow-cleared sidewalk. The trial court held that the Airport had no duty to maintain the grassy area since it provided a sidewalk. The Commonwealth Court agreed, noting that: (1) the depression would have been open and obvious but for the snow; (2) snow has an “inherent tendency to cover uneven patches of ground or other tripping hazards”; and (3) unimproved areas of land by their nature “contain defects that may result in tripping or falling when being crossed on foot.” While the court framed its analysis under an assumption of risk framework, it concluded only that there was no “prima facie case of negligence.” 

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