Is the School Liable for Slip and Fall Injuries In a Puddle of Water ?

In Hanna v. West Shore School District, 679 A.2d 312 (Pa. Cmwlth. 1996), reversed, 548 Pa. 478, 698 A.2d 61 (1997), a woman visiting a school for the purpose of a parent-teacher conference slipped and fell in a puddle of water on the school's corridor and sued for injuries that resulted from the fall. In following the Supreme Court's direction to reconsider the decision in light of Grieff v. Reisinger, 548 Pa. 13, 693 A.2d 195 (1997), this Court reversed the trial court's grant of summary judgment in favor of the school district, and remanded the case for trial, concluding that the plaintiff had pleaded a cause of action that survived the school district's claim that the puddle, not being a condition of the real property, did not result in a waiver of immunity. Hanna v. West Shore School District, 717 A.2d 626 (Pa. Cmwlth. 1998). Rather, the pleadings showed that the district had failed to exercise the proper care, custody, or control over the real property. As the trial court pointed out, the Supreme Court in Kilgore v. City of Philadelphia, 553 Pa. 22, 717 A.2d 514 (1998) (which involved an accumulation of snow and ice on a roadway), held that the City could be held liable under the real property exception for such a condition on a roadway located at City-owned Philadelphia International Airport.