Illinois Compiled Statutes

745 ILCS 75/2 (2026)

Any owner, lessor, occupant or other person in charge of any residential property, or any agent of or other person engaged by any such party, who removes or attempts to remove snow or ice from sidewalks abutting the property shall not be liable for any personal injuries allegedly caused by the snowy or icy condition of the sidewalk resulting from his or her acts or omissions unless the alleged misconduct was willful or wanton

✓ current as of May 2026
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(745 ILCS 75/2) (from Ch. 70, par. 202)
    Sec. 2. Any owner, lessor, occupant or other person in charge of any residential property, or any agent of or other person engaged by any such party, who removes or attempts to remove snow or ice from sidewalks abutting the property shall not be liable for any personal injuries allegedly caused by the snowy or icy condition of the sidewalk resulting from his or her acts or omissions unless the alleged misconduct was willful or wanton.
(Source: P.A. 81-591.)

Notes of Decisions
Cited in 24 cases (1 in the last 5 years), 1996–2023 · leading case: Murphy-Hylton v. Lieberman Mgmt. Servs., Inc., 2016 IL 120394 (Ill. 2016).
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Murphy-Hylton v. Lieberman Mgmt. Servs., Inc., 2016 IL 120394 (Ill. 2016). · cites it 3× “745 ILCS 75/2 (West 2010). -9- liable for injuries “allegedly caused by the snowy or icy condition of the sidewalk resulting from his or her acts or omissions,” unless the conduct was willful or wanton.”
Pikovsky v. North Skokie Boulevard Condo. Ass'n, 2011 IL App (1st) 103742 (Ill. App. Ct. 2011). · cites it 4× “2 Skokie and Rosen claimed that the Illinois Snow and Ice Removal Act (the Act) (745 ILCS 75/2 (West 2008)) granted them immunity from liability for negligence arising out of snow and ice removal on residential sidewalks.”
Murphy-Hylton v. Lieberman Mgmt. Servs., Inc., 2016 IL 120394 (Ill. 2017). · cites it 4× “” 745 ILCS 75/2 (West 2010). ¶ 27 The General Assembly has expressly articulated the public policy of the State and purpose for the immunity under the Act in section 1 as follows: “It is declared to be the public policy of this State that owners and others residing in…”
Hussey v. Chase Manor Condo. Assoc., 2018 IL App (1st) 170437 (Ill. App. Ct. 2018). · cites it 7× “" See 745 ILCS 75/2 (West 2012). We hold that it is not a sidewalk.”
Gallagher v. Union Square Condo. Homeowner's Ass'n, 922 N.E.2d 1201 (Ill. App. Ct. 2010). · cites it 3× “” 745 ILCS 75/2 (West 2008). This immunity from liability is intended to further the public policy and purpose of the Act as stated in section 1 of the Act: “It is declared to be the public policy of this State that owners and others residing in residential units be encouraged…”
Kurczak v. Cornwell, 835 N.E.2d 452 (Ill. App. Ct. 2005). · cites it 3× “JUSTICE BOWMAN delivered the opinion of the court: In this case, we consider whether a paved walkway on residential property constitutes a “sidewalk! ] abutting the property” under the Snow and Ice Removal Act (Act) (745 ILCS 75/2 (West 2000)). On January 7, 2001, plaintiff,…”
Murphy-Hylton v. Lieberman Mgmt. Servs., Inc., 2015 IL App (1st) 142804 (Ill. App. Ct. 2016). · cites it 5× “” 745 ILCS 75/2 (West 2010). ¶ 26 Prior to interpreting the Act and its intended scope, we look to its historical context.”
Ryan v. Glen Ellyn Raintree Condo. Ass'n, 2014 IL App (2d) 130682 (Ill. App. Ct. 2014). · cites it 3× “Second, and alternatively, defendants maintained that plaintiff’s suit was barred by section 2 of the Act (745 ILCS 75/2 (West 2012)), which eliminates liability for injuries resulting from a residential property owner’s acts or omissions in attempting to remove snow or ice from…”
Bremer v. Leisure Acres-Phase II Hous. Corp., 842 N.E.2d 1151 (Ill. App. Ct. 2006). · cites it 3× “See 745 ILCS 75/2 (West 2002). Since Bremer alleged that defendant was negligent for failing to properly remove ice from the sidewalk surface and negligent for allowing an unnatural accumulation of ice on the sidewalk, defendants argued that her complaint should be dismissed.”
Murphy-Hylton v. Lieberman Mgmt. Servs., Inc., 2015 IL App (1st) 142804 (Ill. App. Ct. 2015). · cites it 4× “" 745 ILCS 75/2 (West 2010). ¶ 28 Prior to interpreting the Act and its intended scope, we look to its historical context.”
Flight v. Am. Cmty. Mgmt., Inc., 384 Ill. App. 3d 540 (Ill. App. Ct. 2008). “” 745 ILCS 75/2 (West 2006). Defendants claim that summary judgment was proper because, among other things, plaintiff failed to provide any evidence that he slipped on anything other than a natural accumulation of ice.”
Yu v. Kobayashi, 667 N.E.2d 106 (Ill. App. Ct. 1996). “) 745 ILCS 75/2 (West 1994). Plaintiffs argue that the trial judge erred in dismissing the complaint because they raised an issue of whether the snow on which Lisa Yu fell was located on the "stoop” or on the "sidewalk.”
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