The Massachusetts Supreme Judicial Court removed the distinction between natural and unnatural accumulations of snow and ice on their property. Before this decision, property owners were protected when sued over falls from natural accumulations on their property.

"We now will apply to hazards arising from snow and ice the same obligation that a property owner owes to lawful visitors as to all other hazards: a duty to 'act as a reasonable person under all of the circumstances including the likelihood of injury to others, the probable seriousness of such injuries, and the burden of reducing or avoiding the risk.'"