Buchanan v. TD Bank, N.A.

Summary

The Court affirmed summary judgment for the defendants under the continuing storm doctrine. Because Buchanan fell while freezing precipitation was actively occurring, the doctrine applied and permitted the defendants to wait until the storm ended and a reasonable time thereafter before undertaking remedial measures. The Court also held that the landowner's duty did not require pre-storm salting or other precautionary measures to prevent ice from forming during the approaching storm.