Haydee Gallardo v. Walmart

Summary

The Court held that salting a minimally accumulated snow and ice condition during an ongoing storm did not constitute the unusual circumstances required to impose a duty on a commercial landowner before the storm ended. Because no exception to the ongoing-storm rule applied, Walmart was entitled to summary judgment, as well as judgment at trial and notwithstanding the verdict. The judgment remanding for a new trial was reversed, and the matter was remanded for entry of summary judgment dismissing the claims against Walmart.