Sample Slip and Fall Complaint (Snow and Ice)

If you are looking for a slip and fall complaint sample or a premises liability complaint, this example may serve as a helpful guide. It outlines the basic structure and content commonly found in these lawsuits, hopefully providing insight into how to articulate claims related to slip and fall accidents. Whether you are drafting a complaint for damages for filing, moot court, or the litigation process, this sample premises liability complaint may offer valuable information to assist you in the process.​

In this particular case, the plaintiff suffered a broken arm in a slip-and-fall accident. Despite the severity of the injury, the insurance company declined to offer a meaningful settlement. The case went to trial, and the plaintiff did great on the stand. The jury awarded $370,000, acknowledging the impact of the injury even though the plaintiff experienced a great recovery.

Plaintiff Cindy Foard, by and through her attorneys, Ronald V. Miller, Jr. and Laura G. Zois of Miller & Zois, LLC, files this Complaint against Defendant Aspen Park Homeowners Association, Inc., and alleges as follows:

PARTIES

1. Plaintiff Cindy Foard is an adult resident of Anne Arundel County, Maryland.

2. Defendant Aspen Park Homeowners Association, Inc. (“Aspen Park”) is a Maryland corporation that owns, operates, and maintains the common areas of the Aspen Park residential community located in Anne Arundel County, Maryland. Venue is appropriate in this court because the incident occurred within its jurisdiction, and the defendant conducts business in this area.

FACTUAL BACKGROUND

3. On the morning of January 9, 2024, Plaintiff Cindy Foard stepped outside her home in the Aspen Park community to walk her dog, as she did every morning.

4. A significant snowstorm had occurred two days prior, leaving several inches of snow and ice on the ground. Despite the time that had passed, the sidewalks and parking areas of the community—particularly the stretch directly in front of Plaintiff’s home—remained untreated.

5. Plaintiff and other residents had contacted Aspen Park’s property management multiple times in the days following the storm to report that the walkways were dangerously slick and that no plowing, salting, or other snow removal services had been performed. These warnings were ignored.

6. As Plaintiff walked down the sidewalk that morning, she stepped onto a patch of untreated ice hidden beneath a light dusting of snow. Her feet slid out from beneath her, and she fell forward onto the frozen concrete, bracing her fall with her right arm.

7. Upon falling, Plaintiff experienced immediate and excruciating pain in her right arm and shoulder. Neighbors, alerted by her cries, rushed to assist and found her unable to move her arm. Emergency medical services were summoned, and she was transported by ambulance to the nearest hospital.

8. Diagnostic imaging revealed a comminuted fracture of the distal radius in her right wrist, characterized by multiple bone fragments, along with significant soft tissue damage and severe contusions. The complexity of the fracture necessitated open reduction and internal fixation surgery, involving the placement of metal plates and screws to stabilize the bone. Postoperative recovery was complicated by persistent pain and limited mobility, requiring an extended course of physical therapy and pain management. Despite diligent rehabilitation efforts, Plaintiff continues to experience chronic pain, reduced strength, and restricted range of motion in her right wrist and shoulder. These impairments have significantly impacted her ability to perform daily tasks and have diminished her quality of life.

9. The injuries have profoundly impacted Plaintiff’s daily life. She could not work for several weeks, could not drive, and had to rely on others for routine tasks such as preparing meals and carrying groceries. Even now, months later, she experiences chronic pain and limited range of motion.

10. Plaintiff’s fall and resulting injuries were entirely preventable. The defendant knew about the hazardous sidewalk condition, which should have been addressed in accordance with basic property management standards and community obligations.

COUNT I – NEGLIGENCE

11. Plaintiff incorporates by reference the allegations contained in paragraphs 1 through 10 above.

12. Defendant Aspen Park owed Plaintiff, a resident and lawful user of the property’s common areas, a duty to exercise reasonable care in maintaining those areas in a safe condition.

13. Defendant breached that duty by:

a. Failing to remove accumulated snow and ice from the sidewalk in a timely and reasonable manner;

b. Failing to inspect and identify dangerous conditions on its premises after a known weather event;

c. Ignoring repeated resident complaints and warnings regarding the unsafe condition of the walkway;

d. Failing to implement appropriate snow removal policies or retain competent contractors to treat the sidewalks;

e. Allowing a known and obvious hazard to remain unaddressed for an extended period;

f. Failing to comply with applicable property maintenance standards and community association obligations; and

g. Otherwise failing to exercise reasonable care under the circumstances.

14. As a direct and proximate result of Defendant’s negligence, Plaintiff sustained serious personal injuries, incurred medical expenses, lost wages, and suffered pain, emotional distress, and loss of enjoyment of life.

15. Plaintiff’s injuries were not caused or contributed to by any negligence or fault on her part.

WHEREFORE, Plaintiff Cindy Foard respectfully requests that this Honorable Court enter judgment in her favor and against Defendant Aspen Park Homeowners Association, Inc. for compensatory damages in an amount to be determined at trial, together with costs, interest, and such other relief as this Court deems just and proper.

Respectfully submitted,
Miller & Zois, LLC

Ronald V. Miller, Jr.
Miller & Zois, LLC
1 South Street – 24th Floor
Suite 2450
Baltimore, Maryland 21202
410-553-6000 Phone
844-712-5151 Fax

• Premises Liability Cases in Maryland (an overview)
• Sample Complaints
• Sample Discovery
• Sample Pleadings
• Toolkit for Counsel (guide for lawyers handling personal injury cases)
• Restaurant Slip and Fall Cases (summary of case discussing restaurant’s obligation to consumers)
• Eventually, you will get a motion for summary judgment in any slip-and-fall case. Bookmark this response for when the time comes.