The hills and ridges doctrine is a defense insurance lawyers use in slip and fall on ice cases. The purpose of the hills and ridges doctrine “is to protect landowners from liability for slippery conditions of which the owner may not have notice or sufficient opportunity to make safe.” Gilligan v. Villanova University, 584 A. 2d 1005 (Pa. Super. 1991.) If a homeowner partially shoveled his sidewalk just hours before plaintiff’s accident, he was obviously on notice of the remaining slippery portion of his sidewalk. Accordingly, the hills and ridges doctrine would not be applicable to this case.

The Superior Court in clarifying this purpose of the doctrine stated, “[t]o 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.” Morin v. Traveler’s Rest Motel, Inc. 704 A. 2d 1085, (Pa. Super. 1997), citing, Wentz v. Pennswood Apartments, 518 A.2d 314, (Pa. Super. 1991.) “Snow and ice upon a pavement create merely 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.” Gilligan, supra, at 1007. If the homeowner partially shoveled the walk just hours before the accident, finishing the job hardly imposed an impossible burden on him. He obviously had the time to complete the job. He simply neglected to do so. For this reason also, the hills and ridges doctrine is not applicable to this case.
Further, the doctrine of hills and ridges does not apply in a case where there is no evidence that generally slippery conditions prevailed at the time at the time of the accident. See Williams v. Shultz, 429 Pa. 429, 240 A.2d 812 (1968). The Court in Williams, in addition to holding that generally slippery conditions must prevail before the doctrine will apply, further held that because the plaintiff slipped on an isolated patch of ice, the hills and ridges doctrine did not apply.

By: Evan Aidman