A recent Minnesota Court of Appeals ruling has shed light on the responsibilities of businesses regarding icy conditions in their parking lots during winter months. The case centered around an incident involving Travis J. Maahs, who suffered a severe ankle injury after slipping on ice in a Menards parking lot in Elk River on January 4, 2021.
Maahs, a 49-year-old business owner, had parked his truck in a remote area of the lot due to its size. After shopping, he was loading plywood into his vehicle when he slipped on a small patch of “black ice,” resulting in an ankle injury requiring surgery. Subsequently, Maahs filed a lawsuit against Menards, seeking damages exceeding $50,000 for his injuries, medical expenses, lost wages, and emotional distress.
The lawsuit, initially filed in Sherburne County, alleged that Menards was negligent in failing to inspect the parking lot, treat the ice, and warn customers about hazardous conditions. Menards countered by requesting a summary judgment, arguing that the ice had not been present long enough for employees to notice and address it, and that icy conditions are typical in Minnesota winters, warranting caution from pedestrians.
The Sherburne County court initially ruled in favor of Menards, prompting Maahs to appeal. The appeals court was tasked with determining the extent of Menards’ “duty of reasonable care” to its customers.
Through depositions, it was revealed that Menards had contracted Minnesota Lawn Care for snow removal and de-icing services. The agreement stipulated plowing and one de-icing application for snowfalls of an inch or more, with additional treatment for lesser amounts requiring approval from the store’s general manager.
On the morning of the incident, the general manager had inspected the parking lot but noticed only frost, not considering it a hazard. Other employees testified that while there was no specific company policy for ice removal, they regularly treated high-traffic areas and responded to reports of dangerous conditions.
Maahs argued that Menards’ lack of a formal inspection process contributed to his injury. However, the appeals court rejected this claim, citing previous Minnesota cases that established businesses must protect customers from foreseeable risks but are not absolute guarantors of safety.
The court determined that Menards had no prior knowledge of the specific ice patch and had not created the hazardous condition. It also noted that the store addressed known hazards promptly when informed.
Importantly, the court emphasized that as a lifelong Minnesota resident, Maahs should have been aware of the potential for icy conditions on a winter morning.
This ruling provides clarity on the balance of responsibility between businesses and individuals during Minnesota’s challenging winter months. While businesses are expected to take reasonable precautions and address known hazards, there is an understanding that complete elimination of all icy patches in large outdoor areas may not always be feasible.
The decision underscores the importance of personal caution and awareness for Minnesotans navigating winter conditions, while also maintaining expectations for businesses to implement reasonable safety measures.
As winter approaches, this ruling serves as a reminder for both businesses and residents to remain vigilant and proactive in addressing the challenges posed by icy conditions, recognizing that responsibility for safety is shared between property owners and individuals traversing snowy and icy landscapes.