Blackner v. State Dep't of Transp
In Blackner v. State Dep't of Transp., 2002 UT 44, 48 P.3d 949, a Department of Transportation officer stopped traffic in a known avalanche area after an avalanche had partially buried the road in Little Cottonwood Canyon.
While traffic was stopped, a second avalanche occurred and seriously injured Blackner. Id.
The Court held that the avalanche and the snow pack from which the avalanche originated were natural conditions on public land and that the State was therefore immune from suits arising from injuries caused by the second avalanche. Id.
The snow that caused the injury was a natural condition in physical contact with the land.