The Washington Court of Appeals recently ruled in an unpublished opinion that a man assumed the risk of slipping and falling on accumulated ice and snow in a roadway. As a result, the Court upheld the summary judgment dismissal of his lawsuit against his apartment complex.
Landlords have a general legal duty to keep common areas free from dangerous accumulations of snow and ice, but they are generally not liable for damages caused by dangers that are known or obvious to the injured person. The Court held that the defense of implied primary assumption of risk applied in this case because the injured person had full subjective understanding of the presence and nature of the specific risk and voluntarily chose to encounter that risk.
The Court included a fun footnote near the end of its opinion. During a discussion of the risks posed by snow and ice, the Court mentioned the "proverbial hundreds of Inuit words for snow" and cited a 2013 Washington Post story by David Robson titled There really are 50 Eskimo words for 'snow'. This article observed that "for many of these dialects, the vocabulary associated with sea ice is even richer."
