Illinois Appellate Court
Civil Court
Natural Accumulation
(Court opinion corrected 10/5/11.) Plaintiff sued for injuries sustained from a fall on ice in parking lot owned by one defendant; another defendant was contracted to perform snow removal services for the lot. Plaintiff raised sufficient evidence of genuine factual issues to withstand both defendants' motions for summary judgment. Trier of fact could reasonably find that contractor negligently maintained parking lot, and that property owner had actual or constructive notice of unnatural condition (unnatural accumulation, created by contractor pushing large quantities of snow against building, with snow melting and then freezing into "invisible ice" overnight) which proximately caused Plaintiff's injuries. (QUINN and CUNNINGHAM, concurring.)