An Erie County judge, siding with the defense in a slip-and-fall case, said residents of areas that typically receive a lot of snow and ice should know that a snow-covered hill is likely to be icy and, therefore, slippery.

While the statement by Erie County Common Pleas Judge John Garhart could arguably be considered dicta in an opinion that focused primarily on the application of Pennsylvania’s “hills and ridges” doctrine, Daniel E. Cummins, a defense attorney with the Scranton law firm Foley Cognetti Comerford Cimini & Cummins who is not involved in the case, did note that it was the first time he’d ever seen a judge so explicitly state that the dangers of slipping and falling on snowy surfaces should be obvious to residents of snowy locales.