Frozen Out of Court

In Sanchez v. La Hacienda LLC, the Fifth Court reaffirmed the Texas “natural accumulation rule,” holding that a premises owner has no duty to protect invitees from naturally occurring ice, regardless of whether the owner had advance knowledge of an incoming winter storm.

The appellant argued that the rule should not apply when a landlord knows a dangerous ice condition is “actively forming and worsening” during a prolonged weather event, rather than appearing unexpectedly overnight. The Court rejected this distinction, finding that “nothing in [the supreme court’s leading case] suggests the duration or severity of the storm was legally significant.” Instead, the Court emphasized that ice “results from precipitation beyond a premises owner’s control” and that invitees “are at least as aware as landowners of the existence of [ice] that has accumulated naturally outdoors and will often be in a better position to take immediate precautions against injury.”

No. 05-25-00572-CV, Mar. 10, 2026.