Imagine the following scenarios.
One day, you're walking into a restaurant from your car. It's a sunny day, and the weather has cleared after a snowstorm over a week prior. On your way, you slip on a patch of black ice and severely injure yourself. Who is responsible for your injuries? Is it the restaurant? Their snow removal contractor?
Now change the details a bit: it's snowed much more recently, so there's a light dusting of snow on the ground. However, the weather is otherwise clear and sunny. A person slips and falls—who is responsible now? The injured person, or the restaurant?
Same restaurant, same person, but now it's the middle of a snowstorm. They slip and fall on the ice and suffer the exact same injuries. Who is responsible?
You might be inclined to believe that the injured party is innocent in the first story but responsible in the third. After all, snowy conditions would require someone to be far more cautious—it'd be natural for conditions to be slippery with snow on the ground. The problem of the second scenario is how much snow is required before a landowner is freed from liability.
The question of whether conditions naturally require a person to be more cautious and responsible for their safety rests on the Hills & Ridges Doctrine.
The Law Responds to the Climate
In Pennsylvania, it makes no sense for an individual to claim negligence every time they slip on ice or snow. Temperatures hit between 25 and 44 degrees in winter, and they can get anywhere between 7 and 9 inches of snow a month in the late season. Pennsylvania residents are expected to account for the general terrain wherever they go.
The hills and ridges doctrine requires plaintiffs to prove that the elevation or ridges of the terrain contributed to their injuries—in other words, that there was enough snow to create an actual hazard. "General slippery conditions" aren't enough to prove liability on the part of a landowner, so there has to be an especially hazardous condition present.
The first two scenarios mentioned above are actual cases that were recently handled in Pennsylvania courts. In both cases, the court found that there were no "general slippery conditions," meaning that the plaintiff didn't have to satisfy the hills and ridges test. Essentially, the plaintiff wouldn't be required to expect black ice in a parking lot on a sunny day, one week after a snowstorm cleared up.
However, if there were "generally slippery conditions," then the plaintiff becomes responsible for his or her own injuries.
What makes this doctrine interesting is how tied to the local climate it is. While many laws are founded on principles that apply in any state, local courts exist because local needs exist. Pennsylvania residents live in a different climate from residents in Florida or California—and the law reflects that. Often, that's the reason a local personal injury attorney is going to be a useful resource. Their familiarity with the court's doctrines, procedures, and leanings allow them to create a strategy that addresses the needs of your case.
A premises liability lawyer from Los Angeles will simply have a different background than a premises liability lawyer from Harrisburg—even if both of their practices rest on the same general principles.