Illinois Appellate Court
Civil Court
Natural Accumulation
Plaintiff slipped and fell on icy walkway near entrance of residence she leased from Defendants. Defendants filed Section 2-619 motion to dismiss, alleging negligence claims barred by Snow and Ice Removal Act. Plain language of Act does not provide immunity for injuries if unnatural accumulation of ice was caused by defective construction or improper or insufficient maintenance of premises, and not snow and ice removal efforts. Allegations of willful and wanton misconduct must demonstrate either deliberate intention to harm or a conscious disregard for platntiff's welfare. (STEIGMANN and HOLDER WHITE, concurring.)