In Pennsylvania, liability is ordinarily not created just because a sidewalk is slippery. Conversely, liability will be imposed when there is a dangerous slippery condition that has remained for an unreasonable amount of time.

Stobodzian v. PNC Financial Services Group, et al., arose out of a February 12, 2010 slip and fall that occurred in a PNC Bank parking lot following a substantial snowfall. The plaintiff’s complaint alleged that he slipped on snow/ice while lawfully on the premises of PNC Bank. The plaintiff joined a number of defendants including PNC Bank and those responsible for the snowplowing at the time of the plaintiff’s slip and fall.

At the conclusion of the two-day trial, the jury was charged with a “hills and ridges” instruction, which describes an owner’s duty of care regarding snow/ice on a walking surface. A “hills and ridges” instruction is only appropriate when the general slippery condition results from an “entirely natural accumulation of snow/ice”. Thus, in order for this plaintiff to be awarded damages, the jury must find three essential elements: (1) that ice and snow had accumulated on the walking surface in ridges or elevations that unreasonably obstructed travel and were a danger to persons traveling on the walk; (2) that the defendant property owner knew or should have known of the existence of such conditions; and (3) that it was the dangerous accumulation of ice and snow that caused the plaintiff to fall. Ultimately, the jury determined that none of the defendants were negligent and awarded the plaintiff no damages.

On appeal, the plaintiff raised one issue: the “hills and ridges” jury instruction should not been given. Specifically, the plaintiff argued that the trial court erred in giving the instruction because the snow/ice that the plaintiff slipped on was the result of an “artificial condition created by human intervention”. To support his argument, the plaintiff relied on the fact that vehicles pulling into PNC Bank’s parking lot would drag snow in with them. The Superior Court, however, affirmed the trial court’s use of the “hills and ridges” instruction, adhering to Pennsylvania’s long-standing doctrine used to protect land owners from liability where the owner has not permitted the snow/ice to accumulate.

Thanks to Erin Connolly for her contribution to this post. If you have any questions, please email Paul at