Just in Time for Winter, a Pennsylvania Court Applies the Hills and Ridges Doctrine.

In Koeppel v. PNC Bank, et al., a Pennsylvania, Monroe County, trial court  was confronted with the applicability of the hills and ridges doctrine. In Koeppel, the plaintiff, Karen Koeppel, filed a lawsuit against PNC Bank and Bell Snow Removal LLC. Plaintiff alleged she slipped on ice on PNC Bank’s parking lot. The defendants moved for summary judgment on the basis of the hills and ridges doctrine.

The court initially stated that the hills and ridges doctrine protects an owner of land from liability for generally slippery conditions as long as the owner has not permitted ice and snow to unreasonably accumulate on the property. Further, the court noted that accumulation must be the result of an entirely natural occurrence for the doctrine to apply.

Here, there was no dispute that at the time of the plaintiff’s fall there were generalized icy conditions. The plaintiff, however, contended that the doctrine did not apply because the accumulation, that was the cause of her fall, was not natural. She argued the accumulation was actually the result of the defendants’ snow removal efforts. The court determined that since the plaintiff failed to put forth any evidence to show that the defendants’ snow removal efforts led to the slippery condition that caused her fall, the hills and ridges doctrine would apply. Thus, the defendants’ summary judgment motion was granted and the plaintiff’s complaint was dismissed.