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Case Law Update: Unnatural Accumulation of Snow and Ice Expert Testimony

In Torress v. Midwest Development Company, No. 1-06-3698 (May 19, 2008) 1st div. (R. GORDON), the First District held that the trial court did not abuse its discretion when it barred experts testimony with regards to unnatural accumulation of snow and ice because experts deposition reveals that he could not testify to a reasonable degree of scientific and architectural certainty whether, water stains were present on underside of roof at the time when the plaintiff slipped and fell on the ice, whether ice damming had occurred at time of plaintiffs fall, whether ice or snow was on plaintiffs concrete step at time of his fall, and whether plaintiff had actually slipped on unnatural accumulation of snow and ice at the time of his fall.