In Peters v. United Ref. Co. of Pa., 57 AD3d 1512, 869 N.Y.S.2d 712 (2008), plaintiff argued that a snow plow contractor had "negligently created or exacerbated a dangerous condition by piling mounds of snow on the perimeter of the property, which then melted and re-froze" (id. at 1512).
That Court was not persuaded and granted summary judgment dismissing the action based upon its finding that:
(1) the contract was for plowing, not snow removal; and (2) salting, sanding, or snow removal was to be done upon request only (see id. at 1512-1513).