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New Hampshire Revised Statutes

N.H. Rev. Stat. Ann. § 231:92-a (2026)

Snow, Ice and Other Weather Hazards

✓ current as of May 2026
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    231:92-a Snow, Ice and Other Weather Hazards. – Notwithstanding RSA 231:90-92, a municipality or school district shall not be held liable for damages arising from insufficiencies or hazards on public highways, bridges, or sidewalks, even if it has actual notice or knowledge of them, when such hazards are caused solely by snow, ice, or other inclement weather, and the municipality's or school district's failure or delay in removing or mitigating such hazards is the result of its implementation, absent gross negligence or reckless disregard of the hazard, of a winter or inclement weather maintenance policy or set of priorities adopted in good faith by the officials responsible for such policy; and all municipal or school district employees and officials shall be presumed to be acting pursuant to such a policy or set of priorities, in the absence of proof to the contrary.

Source. 1991, 385:6. 1998, 249:2, eff. Jan. 1, 1999.

Notes of Decisions
Cited in 8 cases (1 in the last 5 years), 1991–2025 · leading case: Cloutier v. City of Berlin, 907 A.2d 955 (N.H. 2006).
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Cloutier v. City of Berlin, 907 A.2d 955 (N.H. 2006). · cites it 10× “Finally, she argues that the trial court’s inclement weather instruction, given pursuant to RSA 231:92-a (Supp. 2005), was erroneous because: (1) RSA 231:92-a is not applicable to the facts of this case; and (2) even if the statute is applicable, the language of the instruction…”
Johnson v. City of Laconia, 684 A.2d 500 (N.H. 1996). · cites it 6× “) determination that the city is not immune, under RSA 231:92-a (1993), from liability for injuries sustained on a municipal parking lot.”
Opinion of the Justices, 592 A.2d 180 (N.H. 1991). · cites it 5× “Proposed RSA 231:92-a reads: “Notwithstanding RSA 231:90-92, a municipality shall not be held liable for damages arising from public highway insufficiencies or hazards, even if it has actual notice or knowledge of them, when such hazards are caused by snow, ice, or other…”
Ford v. New Hampshire Dep't of Transp., 163 N.H. 284 (N.H. 2012). “RSA 231:92-a. The plaintiff argues that RSA 231:91 and RSA 231:92 impose a duty upon the Town with respect to Routes 111 and 28 because RSA 231:91 and RSA 231:92, unlike RSA 231:90, do not refer explicitly to class IV and V highways.”
Trull v. Town of Conway, 669 A.2d 807 (N.H. 1995). “See RSA 231:92-a (1993). Former RSA 231:92 (1982) does not apply because Route 113 is not a “highway which the town has the duty of maintaining.”
Ford v. New Hampshire Dept. of Transp., 37 A.3d 436 (N.H. 2012). “RSA 231:92-a. The plaintiff argues that RSA 231:91 and RSA 231:92 impose a duty upon the Town with respect to Routes 111 and 28 because RSA 231:91 and RSA 231:92, unlike RSA 231:90, do not refer explicitly to class IV and V highways.”
Felts v. City of Rochester, 2025 N.H. 16 (N.H. 2025). “379, 380-81 (1996) (holding that meaning of “highways, bridges, or sidewalks” in RSA 231:92-a does not encompass “parking lots” in part because parking lots may only “on occasion[] be functionally related to highways, bridges, or sidewalks” (emphasis added)).”
Bradford Dutton v. Town of Salem (N.H. 2015). “13, 23-24 (2006) (construing the identical language in RSA 231:92-a (2009)). We agree with the trial court.”
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