Slipped on Ice Outside Work? Why a Minnesota Slip-and-Fall Claim Was Dismissed Before Trial

The Facts

What happened

Jennifer Odegaard worked for a medical-services tenant at the 610 Medical Building in Brooklyn Park, in Hennepin County. On December 27, 2022, she returned from her lunch break and walked from the parking lot toward two waste containers near the north entrance to throw away some trash. She testified that the sidewalk had a light dusting of snow and that she did not see any ice. She slipped, fell on her left knee, and fractured her kneecap. Only after she fell did she see ice where she had landed.

Odegaard sued the company that owned the building, 610 MOB Partners, LLC. Her complaint alleged that the company was negligent in the design and construction of the entrance area and negligent in maintaining the property. She pointed to a roof drain (an "overflow spout") in the overhang above the sidewalk, and to photographs taken after her fall that she said showed the area was often icy or wet.

The building owner asked the court to end the case before trial through a motion for summary judgment. The evidence showed that the property's snow-and-ice contractor had plowed, shoveled, and salted the sidewalks the afternoon before, on December 26, and that weather records showed no significant new snowfall in the days before the fall. Odegaard testified that she used the waste containers almost daily, had never noticed ice there before, did not see ice when she arrived at 8:00 a.m. or when she left for lunch, and did not know how the ice had formed.

The Decision

What the court held

The Court of Appeals, in an opinion authored by Judge Bratvold, affirmed. That means it agreed with the Hennepin County District Court that the case was properly dismissed on summary judgment. See Odegaard v. 610 MOB Partners, LLC, No. A25-1845 (Minn. Ct. App. July 6, 2026). This opinion is nonprecedential. It is not binding authority, although it may be cited for persuasive value as permitted by Minn. R. Civ. App. P. 136.01, subd. 1(c). It illustrates how a Minnesota court applied existing premises-liability law to a specific record.

A property owner in Minnesota has a duty to use reasonable care to protect people from conditions that pose a foreseeable risk of injury, and an ongoing duty to inspect and maintain the property. But owners are "not insurers of safety." To get to a jury on this kind of claim, an injured person generally must present evidence supporting at least one of three things:

• Actual knowledge — that the owner (or its snow-removal contractor) actually knew about the ice; or
• Constructive knowledge — that the ice had been present long enough that the owner should have discovered it; or
• Direct action — that the owner's own conduct actually created the icy condition.

The court concluded that, even viewing the evidence in Odegaard's favor, the record did not create a genuine dispute on any of the three:

• Actual knowledge: No evidence showed that anyone at the building or the snow-removal company knew about this particular ice patch before the fall. Odegaard herself testified she had never noticed ice there and did not know whether anyone else did.
• Constructive knowledge: There was no evidence of how long the ice had been present. The contractor had salted the day before, and no new precipitation followed. Without evidence of timing, the court held that a jury would have to speculate — and, under Minnesota law, speculation about how long a hazard existed is not enough to reach trial.
• Direct action: Although a roof drain sat in the overhang above the sidewalk, no one testified to seeing water drip from it before the fall. The property manager testified she had never seen water flow from the spout and had received no complaints about it. Blaming the drain therefore required speculation.

Odegaard later testified that she returned to the entrance and saw the roof drain actively draining water near where she fell. But she had not seen water dripping before or at the time of the fall, and the court concluded that the later observation did not establish that the drain created the earlier ice patch.

The court did not defer entirely to the district court. It disagreed with the district court's reading of the surveillance video, which was too poor to show the sidewalk surface, and it agreed with Odegaard that she did not have to "conclusively" prove her theory to survive summary judgment. She still had to point to concrete evidence rather than possibilities, and on this record she could not.

Practical Takeaways

What this means for Minnesota injury claims

Minnesota winters produce many slip-and-fall injuries, and these cases can be viable — but they often turn on specific evidence about notice and timing, not simply on the fact that someone was badly hurt. Photographs taken after a fall, and general observations that an area "is usually icy," may not be enough on their own to reach a jury.

The practical lessons that arise directly from this opinion:

• Evidence of how long a hazard existed often matters most. Proof that ice or water was present for a meaningful period — or that the owner was warned about it — may be important to a constructive-notice theory.
• Document conditions promptly. Photographs, video, and witness accounts taken close in time to the fall can help establish when and how a condition formed, before a thaw erases the evidence.
• Maintenance and snow-removal records should be investigated early. Contracts, salting logs, and inspection schedules can help evaluate what the owner knew or did — and may support the claim.
• A drainage or design condition should be investigated, but a theory that a spout or downspout caused the hazard generally needs evidence that water was actually flowing at or before the time of the fall.

Much of this proof — salting logs, timely photographs, and witness accounts — can disappear with the next thaw, so it is often worth pursuing early.

Related reading from Andrade Law:

• how notice is proven in ice-and-snow injury claims
• the evidence that carries a slip-and-fall injury case from report to resolution
• the premises-liability branch of the Ramsey County liability decision tree

Case Information

Case information