Unless there is a statutory provision to the contrary, landowners have no duty to clear snow and ice from public sidewalks adjacent to their property. Mr. Birdsall argues a duty existed because the sidewalk was a common area controlled by Mr. Abrams. The cases he relies on, however, are readily distinguishable because they involve privately owned land. Here, there is no dispute that Mr. Birdsall fell while walking on a publicly owned sidewalk. Mr. Birdsall next argues that Mr. Abrams is liable because he increased the danger by clearing only a portion of the sidewalk.
Landowners are liable for the artificial dangerous conditions they cause.
Here, the snow and ice was accumulated naturally. Mr. Birdsall argues, nonetheless, that this naturally occurring danger was enhanced because Mr. Abrams cleared a portion of the sidewalk, but not the entire sidewalk. Mr. Birdsall relies on Sorenson . In Sorenson , the plaintiff slipped and fell in a privately owned parking lot. Snow and ice had been plowed in the parking lot and piled in various locations.