Hills and Ridges Doctrine May Protect Property Owners in Pennsylvania from Slip and Fall Legal Claims
Snow and ice conditions throughout the state can lead to slip and falls, and injured victims may pursue a personal injury claim against the property owner or responsible party. Throughout Pennsylvania, courts apply the doctrine known as “Hills and Ridges.” This doctrine was set forth in a state Supreme Court case, Rinaldi v. Levine. It serves as a defense that helps property owners facing allegations that they are responsible for a plaintiff’s fall.
The Hills and Ridges doctrine applies to paved areas where people are expected to travel, such as sidewalks. In order to recover damages, plaintiffs must show that ridges or elevations, rather than generally slippery conditions, caused a fall. The dangerous conditions of the ridges or elevations of snow and ice must have been allowed to remain for an unreasonable length of time.
According to the Pennsylvania Supreme Court, property owners are generally responsible for removing ice and snow upon the sidewalk in front of their property. Property owners are not, however, required to keep the sidewalk free from snow and ice at all times. It would be unreasonable to force property owners to keep walkways clear of ice and snow consistently, in light of the region’s climate conditions.
To recover compensation after a fall on snow or an ice-covered sidewalk, an injured plaintiff must show the ice and snow accumulated in ridges or elevations that unreasonably obstructed travel and constituted a danger to pedestrians, the property owner knew through constructive or actual notice of the existence of the condition, and it was this dangerous accumulation of ice and snow that caused the plaintiff’s fall.
The hills and ridges doctrine applies when snow and ice accumulated naturally. If the property owner salted or plowed their property, and someone slipped on the remaining ice, the doctrine would not apply because the accumulations were not “entirely natural.” The owner would have artificially changed them. Snow that melts and then refreezes may not be deemed “natural.” In some situations, the property owner has failed to provide proper drainage of the property, and the hills and ridges doctrine can be defeated by showing that the icy condition was caused by the property owner’s negligence.
The Court in Rinaldi held that property owners must act within a reasonable time after being on notice that the snow and ice were causing a dangerous condition.
At Needle Law, we have helped victims overcome the hills and ridges doctrine. We understand the importance of evidence to personal injury claims of negligence, and we can help you or a loved one following an injury in a slip and fall accident.
Our personal injury attorneys help Pennsylvania residents injured in all types of accidents, from premises liability to product liability. We are skilled at pursuing compensation on behalf of people throughout the state. Contact our office for a free consultation by calling 570-344-1266 or completing our online form.