In Rector v. City of New York, 259 AD2d 319 (1st Dept 1999) the Appellate Division, First Department held that the defendant store was not entitled to summary judgment where it cleared 9-14 inches of snow from an abutting sidewalk, leaving just enough snow to obscure a layer of ice underneath. The court held that "on this record, a jury could readily conclude that defendant's snow removal efforts increased the hazard to pedestrians, producing a surface that is considerably more slick, difficult to discern and inherently dangerous than the natural state of the fallen snow ." (Id., at 321.)