Ice Snow Accidents Cases In Ohio
From a legal point of view, insofar as Stinson v. Cleveland Clinic Found. (1987) is read as holding that ice resulting from' runoff suddenly becomes an "unnatural accumulation" of ice and snow, this proposition of law has been called into doubt by several Ohio courts. Sasse v. Mahle, 1999, Lake App. No. 98-L-157, unreported; Davis v. the Timbers Owners' Association, 2000, Hamilton App. No. C990409, unreported; Community Insurance Co. v. McDonald's Restaurants of Ohio, Inc (Dec. 11, 1998)
Three years after its Stinson decision, the Eighth Appellate District Court itself held that "snow cannot be removed from the sidewalks without being put somewhere.
A certain natural run-off of water is to be expected.... the removal of snow is not an act of negligence, per se" in Hoenigman v. McDonald's Corporation, 1990, Cuyahoga App. No. 56010, unreported.
Thus, assuming arguendo that the patch of ice in question either was what remained after the sidewalk had been salted by Defendant or resulted from run-off water after the piled snow along the sidewalk had thawed, neither of the scenarios alone would render the patch of ice an unnatural accumulation as a matter of law.