Slip and Fall on Snow or Ice in Pennsylvania: Understanding the “Hills and Ridges” Rule 

Winter in Pennsylvania often brings dangerous snow and ice conditions. Every year, people in Wilkes-Barre, Hazleton, Kingston, Plains Township, and throughout Luzerne County suffer serious injuries in slip-and-fall accidents on sidewalks, driveways, and parking lots.

If you were hurt in a fall, you may be wondering whether you can hold a property owner responsible. The answer depends on Pennsylvania's “hills and ridges” doctrine and whether the property owner acted reasonably under the circumstances. Below is what you need to know before filing a claim.

Pennsylvania Law on Snow and Ice Slip-and-Fall Accidents

To recover compensation after slipping on snow or ice in Pennsylvania, the injured person must prove three key elements:

1. Dangerous Accumulation

Snow or ice accumulated in ridges or elevations that created an unreasonable hazard.

2. Notice

The property owner had actual or constructive notice of the dangerous condition. (Constructive notice means the owner should have known about it through reasonable inspection.)

3. Causation

The hazardous accumulation caused the fall and resulting injuries.

What Is Pennsylvania's “Hills and Ridges” Doctrine?

The “hills and ridges” doctrine is a defense that protects property owners from liability for general slippery conditions caused by freshly fallen snow or ice. It recognizes that Pennsylvania winters are unpredictable and that owners cannot keep walkways completely clear during active storms.

Pennsylvania courts have held:

• Property owners are not liable for general icy conditions affecting the entire community. (Tonik v. Apex, 275 A.2d 296 (Pa. 1971)).

• Owners do not have to clear snow or ice while a storm is still in progress.

• They must act within a reasonable time after the storm ends. (Rinaldi v. Levine, 176 A.2d 623 (Pa. 1962); Collins v. Philadelphia Suburban Dev. Corp., 179 A.3d 69 (Pa. Super. 2018)).

• There is no absolute duty to keep property completely free of snow and ice. (Biernacki v. Presque Isle Condominiums, 828 A.2d 1114 (Pa. Super. 2003)).

In short, a property owner is liable only when the snow or ice formed dangerous hills, ridges, or mounds that were left uncorrected for an unreasonable period after a storm.

Does Shoveling or Salting Affect the Doctrine?

Many people wonder whether a property owner loses protection under the hills and ridges doctrine if they shovel or salt during a storm. Pennsylvania courts say no.

Efforts to shovel, plow, or salt during an active storm do not prevent the owner from using the doctrine as a defense.
(See Beck v. Holly Tree Homeowners Ass'n, 689 F. Supp. 2d 756 (E.D. Pa. 2010)).

Exceptions to the Hills and Ridges Doctrine

Not every snow-and-ice case is barred by the doctrine. Important exceptions include:

1. Localized Ice Patches

If the hazard was isolated — not part of a general community-wide condition — the hills and ridges doctrine may not apply.

2. Negligent Maintenance

If the dangerous condition was caused by:

• Improper drainage
• Defective gutters
• Leaking pipes
• Poor design
• Owner neglect
• …then the victim does not need to prove hills and ridges at all.

These situations are common in commercial areas throughout Luzerne County, where drainage and plowing issues often create refreezing hazards.

What To Do After a Slip and Fall on Snow or Ice

To protect your legal rights, take the following steps immediately after the fall:

• Photograph the scene before conditions change or melt
• Take video of the snow, ice, and surrounding area
• Get witness names and contact information
• Seek medical treatment right away
• Preserve shoes or clothing worn during the fall
• Contact a Pennsylvania slip and fall lawyer as soon as possible

Snow and ice cases are extremely time-sensitive, and evidence often disappears quickly.

Local Help for Snow and Ice Accidents in Wilkes-Barre & Luzerne County

If you or a loved one were injured in a snow-and-ice slip and fall in Wilkes-Barre, Plains Township, Kingston, Pittston, Hazleton, or anywhere in Northeastern Pennsylvania, you may be entitled to compensation. These cases are complex and heavily dependent on weather, timing, and evidence.

At Sklarosky Law, we understand Pennsylvania's hills and ridges doctrine and the defenses property owners use. Our firm will investigate the conditions, preserve evidence, and fight to protect your rights.

Call (570) 283-1200 or use our online contact form to schedule a free consultation.
We are ready to help you hold negligent property owners accountable.