A snow removal contractor's tort liability.

Practice point: A snow removal contractor does not assume tort liability in favor of an injured third party unless: (1) the snow removal contractor launched a force or instrument of harm in failing to exercise reasonable care in the performance of its duties; (2) the injured person detrimentally relied on the continued performance of the snow removal contractor's duties; or (3) the snow removal contract entirely displaced the landowner's duty to safely maintain the premises.

Case: Bickelman v. Herrill Bowling, NY Slip Op 02091 (2d Dept. 2008)