RB, Jr., an infant, by and through his next friends, Robby & Corrina Brown v. Big Horn County School District No. 3, 2017 WY 13

RB, a middle-school student, slipped on an obvious patch of ice between school buildings on Feb 20, 2014, sustaining facial injuries. He and classmates had been running and sliding on the ice.
The ice patch was large, visible, of varying thickness; witnesses said it did not appear to be made worse by school actions, though one witness said students added snow to the ice. School maintenance had applied ice melt to the area.
Town precipitation records showed minimal recent snowfall; School District policy was to remove snow and apply ice melt daily when present, and no evidence showed it failed to do so that day.
The district court granted the School District summary judgment, concluding the ice was a natural, open-and-obvious accumulation and no duty arose; RB appealed.
The district court struck RB’s late-filed W.R.C.P. 56.1 statement; the Supreme Court nevertheless accepted the School District’s statement of facts and proceeded to review the legal issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Failure to file W.R.C.P. 56.1 statement	RB: his brief contained facts with citations so failure is not fatal	School Dist.: failure to timely file is fatal to appellate review	Court: not fatal here — accepted defendant’s facts and addressed legal issues because RB challenged legal entitlement to judgment as a matter of law
2. Natural vs. unnatural accumulation (duty)	RB: ice may have been aggravated by District (ice melt) or packed snow; creates fact issue for jury	School Dist.: accumulation was natural and obviously dangerous; no duty to remove	Court: affirmed summary judgment — ice was natural/obvious; no evidence District created/aggravated condition or made it more dangerous
3. Municipal snow-removal ordinance creates duty	RB: Greybull ordinance imposing removal within 24 hours establishes heightened duty	School Dist.: ordinance applies to snow >½ inch, not to ice patch here; not violated	Court: ordinance irrelevant on these facts (no evidence snow formed/packed into ice or that threshold applied); no heightened duty imposed
4. Comparative negligence	RB: his conduct (sliding) raises comparative-negligence issue for jury	School Dist.: no duty exists so comparative negligence need not be reached	Court: because RB failed to make prima facie negligence case, comparative negligence not reached

Amos v. Lincoln Cty. Sch. Dist. No. 2, 359 P.3d 954 (Wyo. 2015) (summary judgment standard in negligence cases)
Gayhart v. Goody, 98 P.3d 164 (Wyo. 2004) (summary judgment review standard)
Watts v. Holmes, 386 P.2d 718 (Wyo. 1963) (adoption of natural-accumulation rule)
Bluejacket v. Carney, 550 P.2d 494 (Wyo. 1976) (proprietor not negligent for natural ice accumulation)
Eiselein v. K-Mart, Inc., 868 P.2d 893 (Wyo. 1994) (unnatural accumulation found when owner creates or substantially alters condition)
Pullman v. Outzen, 924 P.2d 416 (Wyo. 1996) (test for unnatural accumulation: created/aggravated hazard, knowledge, substantially more dangerous)
Valance v. VI-Doug, Inc., 50 P.3d 697 (Wyo. 2002) (natural forces and duty analysis; open-and-obvious danger doctrine)
Paulson v. Andicoechea, 926 P.2d 955 (Wyo. 1996) (packed/frozen snow as natural accumulation)
Selby v. Conquistador Apartments, Ltd., 990 P.2d 491 (Wyo. 1999) (facts may show defendant aggravated accumulation by placement of structures)
Pinnacle Bank v. Villa, 100 P.3d 1287 (Wyo. 2004) (municipal ordinance may create heightened duty though violation is not negligence per se)