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Case Law Update: Summary Judgment in Slip and Fall

Ciciora v. CCAA, Inc. No. 08-1099 (9/4/09) affirmed that the district court did not err in granting defendants’ motion for summary judgment in action seeking recovery for personal injuries sustained when plaintiff fell on patch of ice on shoveled sidewalk leading to entrance of defendants’ restaurant. Plaintiff failed to present any evidence that her fall was result of unnatural accumulation of snow or ice where plaintiff admitted that sidewalk was clear and dry at time she exited her vehicle, and that no ice was visible when she began to walk on sidewalk. Moreover, plaintiff could only speculate that nearby awning was cause for accumulation of ice. This seventh circuit case will greatly impact slip and fall cases.