Superior Court Held There Was No Factual Dispute to Overcome Summary Judgment When Plaintiff’s Own Admissions Established that Hills and Ridges Doctrine and Assumption of Risk Doctrine Barred Recovery.

The plaintiff, an invitee, slipped and fell on an icy ramp while he walked into work. The defendants, including the property owner and a snow removal contractor, filed motions for summary judgment that argued the hills and ridges doctrine and assumption of risk doctrine barred the plaintiff from recovery. The trial court granted the motions, and the plaintiff appealed. 

With regard to the hills and ridges doctrine, the Superior Court of Pennsylvania held that the plaintiff failed to present any evidence to establish the defendants permitted ice to accumulate in ridges or elevations to unreasonably obstruct travel. The Superior Court also ruled there was no evidence to support the plaintiff’s contention that the defendant-contractor’s antecedent’s negligence caused or contributed to the dangerous condition of the ramp. 

Instead, the Superior Court found that the plaintiff’s own testimonial admissions established the requisite elements of the doctrine. The court rejected the argument that the hills and ridges doctrine was not applicable to the defendant-contractor, reasoning that a snow removal contractor is equally protected by the hills and ridges doctrine to the same degree as a landowner. 

The court further held that the assumption of risk doctrine applied when the plaintiff’s admissions established that he voluntarily and knowingly proceed in the face of an obvious, dangerous condition. Therefore, the Superior Court affirmed the trial court’s order. 

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