Korcz v. United States of America

On April 18, 2023, the U.S. Court of Appeals for the Federal Circuit issued its decision in Korcz v. United States of America. Plaintiff Linda Korcz slipped and fell on black ice in a post office parking lot in Pennsylvania, sustaining injuries. She sued the United States under the Federal Tort Claims Act, alleging that the U.S. Postal Service was negligent in failing to clear the ice. The district court granted summary judgment for the government, ruling that under Pennsylvania law, the Postal Service had no duty to remove naturally accumulating ice and that the snow removal contractor was an independent contractor whose negligence could not be imputed to the government. The Federal Circuit affirmed, holding that Korcz failed to establish that the government owed or breached any actionable duty of care.

The Federal Circuit affirmed the district court's grant of summary judgment in favor of the United States, dismissing Linda Korcz's negligence claim with prejudice. The government bore no liability for her slip-and-fall injuries.

Whether the United States Postal Service owed a duty of care to business invitees to clear black ice from its parking lot under Pennsylvania premises liability law, and whether the alleged negligence of an independent snow removal contractor could be attributed to the federal government under the Federal Tort Claims Act.

The ruling reinforced the limited waiver of sovereign immunity under the FTCA regarding natural accumulations of ice and snow on federal property. It clarified the independent contractor exception in premises liability actions against the United States, providing significant legal protection for the Postal Service and other federal agencies against similar slip-and-fall claims.