Unnatural accumulations include snow piles created by snow removal and ice formed by artificial conditions, such as a fountain. For example, the Illinois Supreme Court recently ruled that it was proper to hold a county responsible for an automobile accident. The accident occurred when a motorist's view was obstructed by a snow pile that was created when the county cleared the intersection of snow. In this case, the plaintiff had to show that the snow pile, which was higher than the plaintiff's car, was an unnatural accumulation of snow placed at the intersection and that the county knew of this dangerous condition. Since the evidence demonstrated that county workers created the dangerous condition when they plowed, it was not difficult to establish that they knew of the snow pile, its size and height, and its dangerous location at the corner of an intersection.
Illinois law recognizes the common-sense approach to snow and ice removal.
If you remove snow and ice from your property, do it in such a way that you do not create another condition that could result in injuries to others. Doctors contract with the HMO to treat a certain number of the members for a fixed price. In recent years, however, this system has come under scrutiny because it could discourage doctors from providing the best, most comprehensive medical care. In the past, the law has shielded HMOs from liability for the treatment rendered by their doctors. The court ruled that an HMO may be held vicariously liable for the negligence of its participating doctors based upon two theories of recovery.