Article ID: f7c6e29e737c4ed8a8d912fcb9d6bea126ccb2c3f6e9349055a870c7603b8120
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URL: https://www.businessinsurance.com/employer-had-no-duty-to-protect-worker-from-icy-sidewalk/
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Employer had no duty to protect worker from icy sidewalk - Business Insurance Skip to content Register for free Search Search Log In Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Employer had no duty to protect worker from icy sidewalk by Work Comp Central Claims Disputes , Workers Comp Coverage , Workplace Safety Mar 9, 2026 A Texas appeals court affirmed summary judgment for a senior living facility in a nurse’s slip-and-fall lawsuit, finding the employer had no duty to protect her from naturally accumulated ice and did not assume such a duty by attempting to clear sidewalks. The Court of Appeals for the 7th District of Texas said in Patricia King v. ER OPCO Craig, d/b/a The Craig Senior Living , issued Wednesday, that property owners generally have no duty to remove naturally occurring ice and snow, and Texas law imposes no general obligation to act as a “good Samaritan.” A duty can arise when a party voluntarily undertakes services necessary for another’s protection and fails to exercise reasonable care, increasing the risk of harm or causing harm through reliance on the undertaking, the court said. Patricia King, a licensed vocational nurse, slipped on an icy sidewalk after finishing her shift at the Craig Senior Living facility in February 2022. She broke her hip and crawled back to the entrance, where automatic doors repeatedly opened and closed on her until coworkers assisted her. Ms. King underwent hip surgery and was treated for frostbite and hypothermia before returning to the facility for rehabilitation. She later sued Craig for her injuries. The trial court granted summary judgment for the facility, finding she failed to show the employer owed her a duty or caused her injuries. On appeal, Ms. King argued the facility assumed a duty when a company official told employees sidewalks would be cleared. The appellate court said that even if the statement constituted a voluntary undertaking, she could not show the facility increased the risk of harm or that she reasonably relied on the effort. The court said attempts to salt or shovel ice do not alter the natural condition of winter weather. “King was left in precisely the position the weather placed her, not in a worse position caused by the defendant’s conduct,” the court said. The court also rejected her reliance argument, noting the employer merely said staff would do their best to clear the sidewalks despite continuing snowfall. Finally, the court said the facility’s status as a Texas workers compensation nonsubscriber did not affect the outcome because Ms. King failed to show the employer breached any legal duty. WorkCompCentral is a sister publication of Business Insurance. More stories here . 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