In Espinal v. Melville Snow Contrs., 98 NY2d 136, 138, 773 N.E.2d 485, 746 N.Y.S.2d 120 [2002], the plaintiff slipped and fell in an icy parking lot, and sued the owner's snow removal contractor (Espinal, 98 NY2d at 138). The Court held that this exception did not apply, because, under the terms of its contract, the owner "at all times retained its landowner's duty to inspect and safely maintain the premises" (id. at 141). The Court of Appeals set forth three instances in which a party to a contract to render services is considered to have assumed a duty of care and thus, are liable to third persons: (1) where the contracting party, in failing to exercise reasonable care in the performance of his duties, "launches a force or instrument of harm": (2) where the plaintiff detrimentally relies on the continued performance of the contracting party's duties ; (3) where the contracting party has entirely displaced the other party's duty to maintain the premises safely . These principles are firmly rooted in our case law, and have been generally recognized by other authorities. In short, after a slip and fall in a parking lot, the plaintiff commenced an action against the owner of the parking lot, as well as the contractor that was responsible for snow and ice removal. The plaintiff claimed that the contractor created a dangerous and icy condition that caused her to fall. In affirming the appellate court's granting of the contractor's motion for summary judgment, the Court of Appeals held that a "contractual obligation, standing alone, will generally not give rise to tort liability in favor of a third party". Espinal, 98 NY2d at 139.