Under the storm-in-progress rule, a property owner[or, where relevant, a snow removal contractor will not be held responsible for accidents occurring as a result of the accumulation of snow and ice on its premises until an adequate period of time has passed following the cessation of the storm to allow the owner an opportunity to ameliorate the hazards caused by the storm.
Walker v. Jonis Holdings II, LLC, NY Slip Op 07038 (2d Dep't December 17, 2025)