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															..., removing top layer of snow.  
  O.Jur 3d Premises Liability §§ 3, 33.  
  Ordinarily, a landowner is not liable  for injuries resulting ...of law, predicated upon the general principle that the owner of a premises has no liability to a person injured on the premises as a result of a natural accumulation of snow and ice. While conceding....  
  
 
 
  Torts — Negligence — Liability of landowner for injury to invitee due to accumulated ice and snow — Accumulation is "natural," when — Par...
														
															...365.  
  ¶ 4 Apparently, the district court regarded the rule of Buck as an inflexible and absolute rule of law — that under no circumstances may a premises liability claim be maintained for an accident a...district court, noting there had been no showing of any act by the premises owner tending to enhance or exaggerate the natural accumulation as in...a factual controversy over whether the plaintiff's slip and fall was caused by a natural accumulation of ice and snow or by an increased hazard caused by the premises owner's placement of a drain pipe...
														
															...cannot justify the distinction we now abandon.  
 The second justification offered for the natural accumulation rule is that enforcement of an affirmative obligation to remove natural accumulations of snow ...in Reardon v. Shimelman, 102 Conn. 383 (1925), rejecting the Massachusetts rule of natural accumulation and adopting instead a rule requiring a landlord to exercise reasona...followed the Connecticut rule rather than the Massachusetts rule of natural accumulation. See id. at 8A-122 — 8A-123. See also G. Weissenberger B.B. McFarland, Premises Liability § 4.6, at 102-104...
														
															..., no pet.) (mem.op.) ("[T]he natural accumulation of ice-is not unreasonably dangerous for purposes of premises liability."); Smith v. Shofner Auto Repair, Inc., No. 02-08-285-CV...to support a premises liability claim.    
 B. Scott and White established that the ice was in its natural state.  
 .... LEXIS 6403, at *9-*10 (distinguishing a case involving ice created by a leaking vending machine because it was not a natural accumulation); Surratt, 102 S.W.3d at 439...
														
															...summary judgment. In doing so, the court held that: (1) Texas law bars Appellants from bringing a general negligence claim in this circumstance; (2) the natural accumulation doctrine precludes Appellants from prevailing on a ..., the natural accumulation doctrine applies, and Appellants' premises liability claim fails as a matter of law because Appellants cannot establish an unreasonable risk of harm.  
  C...sections III(A) and III(B) of this opinion, Texas law clearly limits injured persons to bringing either a general negligence claim or a premises liability claim. Occidental Ch...
														
															...liability before concluding that a natural accumulation of frozen precipitation on a parking lot does not constitute an unreasonably dangerous condition...Liability  
   A premises owner owes a duty to an invitee "to exercise reasonable care to protect against danger from a condition on the land that creates an unreasonable risk of harm...determining a premises owner's duty in this situation. See id. at 442 (citing Jay Zitter, Annotation, Liability of Owner, Operator, or Other Parties, for Personal Injuries Allegedly Resulting from...
														
MOTIONS (Beta)
															...appreciated, or obvious.” 
  Id. (citing 57A Am. Jur. 2d Negligence § 388 (1989)). 
  
 
   Under the natural accumulation rule a landowner has no duty to remove, and is not liable for injuries caused...whether a duty exists. 
  See Gunville v. United States, 985 F.Supp.2d 1101, 1108 (D.S.D. 2013) ("The natural accumulation rule concerns the threshold question of whe...caused by natural accumulation of ice and snow. 
  See 62A Am. Jur. 2d Premises Liability § 625...
														
															.... Papenhausen sued the Defendants, asserting claims of negligence and premises liability under North Dakota law.  
  [¶4] Papenhausen alleges the cause of the injury was an unreasonably dangerous hole concealed by i..., or obvious." Id. (citing 57A Am. Jur. 2d Negligence § 388 (1989)).  
  [¶9] Under the natural accumulation rule a landowner has no duty to remove, and is not liable for injuries caused by, ...threshold question whether a duty exists. See Gunville v. United States, 985 F.Supp.2d 1101, 1108 (D.S.D. 2013) ("The natural accumulation rule concerns the threshold...
														
MOTIONS (Beta)
															...Allegedly Resulting from Snow or Ice on Premises of Parking Lot, 74 A.L.R.5th 49, § 2[a] (1999). Under the natural accumulation or Massachusetts rule, “a property owner has no duty to remove, and is not liable for injur...§ 52:1 (West 2013); see also62A Am.Jur.2d Premises Liability § 656 (2005) (explaining that under the natural accumulation rule...Am.Jur.2d Premises Liability § 656.   
 Some states follow the natural accumulation rule, but have developed exceptions to its application. For instance, Ohio follows...
														
															...required to protect herself against falls." In other words, although appellants knew of the hazardous condition created by the natural accumulation of ice and snow, so, too, as a matter of law, did their guests. ..., reversed the judgment of the trial court. The court of appeals' majority held that when a homeowner knows of a hazardous condition on the homeowner's premises caused by a natural accumulation of ice...court held that:  
  "1. When the owner or occupier of business premises is not shown to have notice, actual or implied, that the natural accumulation of snow and ice on his premises...
														
MOTIONS (Beta)
															...Plaintiffs' claim that the gate should have been locked sounds in premises liability, not general negligence, and, accordingly, fails as a matter of law under the natural accumulation doctrine. ECF...premises liability, the Court agrees with the Government that the claim is barred by the natural accumulation doctrine. The natural accumulation doctrine bars premises liability ...naturally occurring conditions like ice, rain, and mud, by negating the second element of a premises liability claim- proof of an “unreasonably dangerous condition” on the property. M.O. Dental Lab v. Rape, 139 S.W.3d at 675-...
														
															....  
  
 
 
  Negligence — Snow removal — Landowner may be liable when removal of snow causes more dangerous condition than before removal.  
  O.Jur 3d ...the general rule that a landowner has no duty to remove a natural accumulation of ice and snow.  
 
  QUILLIN, P.J....  
  The question presented by this appeal is whether a landowner who attempts to remove a natural accumulation of ice and snow and thereby causes a condition more dangerous than before...
														
															...to the natural accumulation of snow and ice on defendant's premises was prejudicial error. The predicate of defendant's liability under the proof was not the breach of a duty to remove the natural...related to the duty of the defendant to remove the natural accumulation of snow and ice from premises used by defendant's customers as voiced in Grizzell v. Foxx, supra. A second instruction related to..., 332 S.W.2d 692. The proprietor's liability is predicated on his superior knowledge of the dangerous condition on his premises and he is not...
														
MOTIONS (Beta)
															...premises liability claim." Scott & White Memorial Hospital v. Fair,  310 S.W.3d 411, 414 (Tex. 2010). See ...sufficient to create a disputed issue of material fact in this case. While the Court does not go so far as to say that the natural accumulation of ice may never support any premises liability theory..., 77 A.2d 645, 646-47 (1951).  
 There are two documented exceptions to the Scott & White natural accumulation rule: (1) when the ...
														
															.... Id . 
  [¶14] In Wyoming, we apply the natural accumulation rule to premises liability claims. That rule provides: 
  
  
   [A...natural accumulation" such that the owner of the premises was not liable for injuries sustained as a result of a slip and fall on that accumulation. Id . at 418...? 
 2. Is the question of whether there was a natural accumulation of snow and ice a fact issue that should have been submitted to a jury? 
 3. Does the Greybull snow...
														
															...estate has no liability for a natural accumulation of ice or snow upon the premises where the evidence shows that the ice condition formed through the operation of the forces of nature...accumulating on walkways, public or private, can be the source of liability on a theory of negligence. The maintaining of an artificial structure, or something which causes an unnatural accumulation...for personal injury as the result of a fall on the premises of the defendant on January 9, 1977. The trial judge found that the plaintiff was a social guest at the defendant's home shortly before his...
														
															...negligence and premises liability. The district court determined appellant's claims were barred by the obvious danger and natural accumulation rules.  
  We reverse and remand for a new...danger and protect himself against it.
    
  62A AM.JUR.2d Premises Liability § 699 (1990).  
  The justification for the natural-accumulation rule..., the rule remains that an owner or occupier of premises will not be liable for injuries resulting from a slip and fall on a natural accumulation of ice and snow. Having determined the natural...
														
															...injuries resulted from Wal-Mart's purported negligence (count I) and its violation of the Illinois Premises Liability Act (740 ILCS 103/1, et seq. (2014)) (count II). Wal-Mart filed an answer denying the material allegations ...violation of the Premises Liability Act. We need not address the specifics of this count any further however, as our supreme court has recognized that a conclusion that a plaintiff's negligence claim fails under the natural...is dispositive of any related claim under the Premises Liability Act. Poke v. Illinois Power Co., 187 Ill. App. 3d 631, 635 (1989). 
 ...
														
															...from a slip and fall on a natural accumulation of snow and ice on or about a common use area of necessity?
    
  
    A) Was the icy area on which...depending on the presence or absence of cloud cover surely must be the slipperiest slope of all in this area of premises  liability jurisprudence. A determination whether t...the adoption of comparative negligence. Simply expressed, the natural accumulation rule provides that an owner or occupier of premises is not liable for injuries resulting from a slip and fall on a...
														
															...risks presented by natural accumulations of ice and snow. Brinkman, supra.  
  {¶ 4} Conversely, liability may result if the premises owner permits an unnatural accumulation...in the instant claim, the court concludes the ice and snow that damaged plaintiff's car was a natural accumulation. Ordinarily, defendant would be relieved from legal liability for injury resulting from this ....  
  {¶ 2} Defendant denied any liability in this matter. Defendant pointed out plaintiff's property damage was the result of a falling natural accumulation of ice and snow and therefore, the...
														
 
						 
					