Illinois Appellate Court
Civil Court
Natural Accumulation
Snow and Ice Removal Act bars Plaintiff's negligence suit as a matter of law. Plaintiff slipped and fell on a patch of ice just outside entrance of a building within condominium complex, within a common area of complex. Plaintiff alleged that ice had formed because of water dripping from overhead awning and then freezing on walkway below. Although Plaintiff alleged that ultimate cause was defect in awning, the more immediate cause alleged is a lapse in Defendants' voluntarily undertaken snow and ice removal efforts. Thus, Snow and Ice Removal Act has prima facie application to her claim. (HUTCHINSON and SPENCE, concurring.)