Bloch v. Herman's Sporting Goods

In Bloch v. Herman's Sporting Goods, 208 Ga. App. 280 (430 SE2d 86) (1993), the plaintiff drove to the defendant's store when the temperature in the area had been freezing for several days. When she arrived at the store, she saw ice accumulations on the shopping center's gutters, on the curb and on part of the sidewalk. She chose to step on an area that appeared to be clear of ice, but was covered in puddles of water. She slipped on what she believed to be "invisible" ice under the water. Bloch, 208 Ga. App. at 280. The Court affirmed summary judgment to the defendant, holding that "knowledge of a puddle of water surrounded by ice, coupled with knowledge of the generally prevailing weather conditions, is knowledge of a probable danger of encountering additional ice under the surface of the water." Id. at 281.