• A Pennsylvania appeals court ruled that a Catholic church and diocese were not responsible for the injuries sustained by a woman who slipped and fell on an icy church parking lot. The woman, who was attending the church to participate in a bingo game, alleged that the parking lot was covered with a sheet of ice and also 5 inches of new snow. She alleged that the church had been negligent in failing to "implement some remedial measure (placing salt or ashes, warning visitors of the presence of ice, or barricading the icy area)," and accordingly the church was responsible for her injuries. A trial court ruled in favor of the church, and the woman appealed. A state appeals court agreed that the church was not responsible for the woman's injuries. It observed:
[A]n owner or occupier of land is not liable for general slippery conditions, for to require that one's walks be always free of ice and snow would be to impose an impossible burden in view of the climatic conditions in this hemisphere. Snow and ice upon a pavement create merely a transient danger, and the only duty upon the property owner or tenant is to act within a reasonable time after notice to remove it when it is in a dangerous condition …. [I]n order to recover for a fall on an ice or snow covered sidewalk, a plaintiff must prove (1) that snow and ice had accumulated on the sidewalk in ridges or elevations of such size and character as to unreasonably obstruct travel and constitute a danger to pedestrians traveling thereon; (2) that the property owner had notice, either actual or constructive, of the existence of such condition; (3) that it was the dangerous accumulation of snow and ice which caused the plaintiff to fall.