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Illinois’ First District Appellate Court Releases New Ruling Regarding Natural Accumulation Liability

A new natural accumulation rule for property owners in Illinois was introduced regarding liability for slips and falls due to ice or snow: Mickens v. CPS Chicago Parking, LLC, et al, 2019 IL App 1st (180156).

Traditionally in Illinois, property owners, property managers and snow removal contractors are not generally liable for natural accumulations of ice and snow on their property. However, Illinois’ First District Appellate Court confirmed that removal contractors and property managers could be liable for any natural accumulations on premises where they are contracted to remove snow. The Court reasoned this amounted to a voluntary undertaking that expanded contractors’ duties to include removing natural accumulations.

If this decision stands, it could pose a significant change to the longstanding natural accumulation rule and signal future changes for property owners. To learn more about premise liability or how this decision may impact your personal or business property, contact Joseph P. Sullivan at 312.781.6559 or Paul A. Ruscheinski at 312.781.6602.