It depends. If the town has a certain schedule to salt the street, and the accident occured prior to the reasonable amount of time it would have taken the hired agents to salt the street, then it is not the town's liability. 5 hours after snowing is a relative situation. It depends on if the snow was so bad that no road crews could get out. Individuals are also not absolved of each of their own responsibilities to use reasonable thought in driving. So in terms of your particular accident, you should probably see the copy of the police report and see what the officer's take is and possibly consult with a personal injury or accident litigation attorney to see if you have any possibility in successfully suing the town.