IL · jury_instructions
Ill. Pattern Jury Instr. (Civil) 125.02
Falls On Ice Or Snow --Negligence Only--No Issue As To Ownership Or Control --
Issues/Burden Of Proof
[In Count __], plaintiff [plaintiff's name] seeks to recover damages from the defendant
[defendant's name]. In order to recover damages, the plaintiff has the burden of proving:
First, there was an unnatural accumulation of [ice] [snow] on the [property] [land]
[building] [other] which presented an unreasonable risk of harm to people on the property.
Second, the defendant knew or in the exercise of ordinary care should have known of
both the condition and the risk.
Third, the defendant could reasonably expect that people on the property [would not
discover or realize the danger] [or] [would fail to protect against such danger].
Fourth, the defendant was negligent in one or more of the following ways:
a) ________,
b) ________,
c) ________,
Fifth, the plaintiff was injured.
Sixth, the defendant's negli gence was a proximate cause of the plaintiff's injury.
Provenance
- Source
- illinoiscourts.gov
- Retrieved
- 2026-08-20
- Edition
- 2026-08-19
- Content hash
b24a410281ae793b54b83feb572fb9b731df8466528b961fab580df5aadfdac8
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