On Feb. 9, 2012, plaintiff Wanda Williams, a part-time custodian in her early 50s, parked her car in the parking lot of IBS Communications Inc., in Wyndmoor. She was an independent contractor who performed custodial services at the company. As Williams exited her car, she slipped on black ice and braced herself with her right arm. As she regained her footing, she slipped again and fell on her knees. She suffered a right-shoulder rotator-cuff injury.

Williams sued IBS Communications and property-owner DAB LLC, alleging that they were negligent for failing to remediate the ice from the parking lot.