McAuley v. United Cigar Stores Company of America, Inc

In McAuley v. United Cigar Stores Company of America, Inc. (204 AD 356 [1st Dept. 1923]) the court vacated the jury's verdict against defendant, the owner of a store, at the entrance to which, plaintiff allegedly fell on an accumulation of snow and ice because only six hours had elapsed between the cessation of a heavy snow storm and plaintiff's alleged accident and because the accident occurred at a time - 11PM - when snow removal efforts would not normally be undertaken.