In Negron v. Warriner’s Construction Co., Inc., the Law Division of the Superior Court of Cumberland County, NJ granted summary judgment to three defendants in a case concerning a slip and fall in a bank parking lot. The plaintiff fell while using the parking lot as a shortcut while walking from a store to his apartment. The plaintiff claimed that he fell on ice that was covered by a light coating of snow that had fallen within 30 minutes of the accident. The motion for summary judgment was filed by three of the four defendants, including the landowner, possessor of the land, and a snow and ice removal contractor.

The Court noted that as the plaintiff was a trespasser, the defendants’ duty was limited to warning the plaintiff of artificial conditions on the property that posed a risk of death or serious bodily injury. As the Court observed, the subject accident was not caused by an artificial property condition. The Court further observed that the bank had taken reasonable care to plow and salt the parking lot after snow showers earlier in the day, and that the bank had no “reasonable opportunity” to address the evening’s additional snow showers before the accident occurred. The Court therefore concluded that no reasonable jury could find that the moving defendants violated any duty owed to plaintiff, and granted summary judgment in the defendants’ favor.