Church Not Responsible for Parking Lot Injuries

Employees were not aware of slippery conditions.

Key point: Churches ordinarily cannot be responsible for snow or ice-related slips and falls in their parking lots unless they were aware of a dangerous condition and had a reasonable opportunity to correct it.

A New York appellate court ruled that a church was not legally responsible for injuries sustained by a woman who slipped on a patch of ice in the church parking lot.

The woman had attended a meeting of a local community group on the church's premises. On her way to her car, she slipped and fell on a patch of snow-covered ice and sustained serious injuries. She sued the church. The court ruled that the church was not responsible for the accident, since it was not aware of the ice and snow accumulation (no church employees were present at the time of the meeting) and the church did not have a reasonable opportunity to remove the snow and ice.

The icy condition developed only two hours before the accident, and the snow (that concealed the ice) began falling only 15 minutes prior to the accident. Under these circumstances the court concluded: "[The church] as the owner of the premises, had a duty to exercise reasonable care under the circumstances. In order to impose liability upon [the church] there must be evidence that it knew, or in the exercise of reasonable care should have known, that an icy condition existed in its parking lot. Additionally, a party in possession or control of property is afforded a reasonable time after the cessation of the storm or temperature fluctuation which created the dangerous condition to exercise due care in order to correct the situation."

There simply was not sufficient time in this case for the church to have removed the snow or ice prior to the accident, and accordingly the church was not legally responsible for the woman's injuries. Byrd v. Church of Christ, 597 N.Y.S.2d 211 (A.D. 3 Dept. 1993).

See Also: Premises Liability

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