delivered the opinion of the court:
Plaintiffs, Kevin E. Kellermann and Kathleen A. Kellermann, appeal the circuit court of Clinton County’s dismissal of counts IV and V of their second amended complaint filed against defendant, Car City Chevrolet-Nissan, Inc. (Car City). Counts IV and V of the complaint allege that, due to defendant’s negligence, plaintiffs sustained injuries when Kevin slipped and fell on snow which had accumulated on defendant’s sales lot. The circuit court applied the natural-accumulation rule, finding that defendant was not liable for injuries incurred by plaintiffs when Kevin slipped and fell on snow which had naturally accumulated on defendant’s lot. Plaintiffs now appeal the dismissal of counts IV and V of their amended complaint, arguing that the natural-accumulation rule should not apply. For the following reasons, we affirm the decision of the circuit court.
On January 18, 1997, Kevin Kellermann and his wife, Kathleen, were walking on the auto sales lot of Car City in Centralia, Illinois. The lot is outdoors and contains numerous automobiles and trucks that are placed on display to allow an inspection by potential customers. According to the complaint, snow accumulated on the lot, making the lot “slick, icy[,] and hazardous.” Plaintiffs do not allege that the accumulation of snow was unnatural or that a dangerous condition was created by defendant. The complaint does not describe the size of the auto sales lot, the size of the display area on the auto sales lot, or whether Kevin was distracted by anything on the lot.
In their complaint, plaintiffs allege that defendant was negligent for (1) failing to maintain a safe car sales lot, (2) failing to remove the accumulation of snow and ice, (3) failing to place salt or cinders on the snow and ice, (4) failing to barricade the area containing the slick snow and ice, (5) failing to prevent customers’ access to the area containing the snow and ice, (6) failing to warn the customers of the snow and ice, and (7) displaying the vehicles on the snow and ice when defendant knew that potential customers would go upon the area to examine the vehicles.
On January 17, 1998, the circuit court conducted a hearing concerning plaintiffs’ second amended complaint. Although plaintiffs apparently requested that the circuit court create an exception to the natural-accumulation rule, the circuit court stated, “Perhaps such an exception should and may some day be created by the higher courts [;] however[,] at this time it appears clear to this court that under the general rule stated in Timmons v. Turske, 103 Ill. App. 3d 36 (1981), a property owner is not liable for injuries resulting from an icy condition which is a natural one.” Accordingly, the circuit court dismissed plaintiffs’ second amended complaint with prejudice. We shall now review this decision by the circuit court and address plaintiffs’ arguments on appeal.
We review de novo the circuit court’s dismissal of plaintiffs’ complaint for the failure to state a cause of action. See Kotarba v. Jamrozik, 283 Ill. App. 3d 595, 596 (1996). Under a de novo standard of review, we need not give deference to the circuit court’s decision. See Von Meeteren v. Sell-Sold, Ltd., 274 Ill. App. 3d 993, 996 (1995).
In the instant case, plaintiffs allege that defendant was negligent in maintaining its sales lot. In a negligence action, one of the essential elements is the existence of a duty to exercise reasonable care. See Unger v. Eichleay Corp., 244 Ill. App. 3d 445, 449 (1993). The question of whether a duty is owed is a question of law. See Roberson v. J.C. Penney Co., 251 Ill. App. 3d 523, 526 (1993). If defendant does not owe a duty to plaintiffs to exercise reasonable care, then no cause of action for negligence will exist. See Sparacino v. Andover Controls Corp., 227 Ill. App. 3d 980, 986 (1992).
It is the general rule in Illinois that a landowner or a possessor of land has a duty to an invitee or a licensee to exercise ordinary or reasonable care in maintaining his premises in a reasonably safe condition. See Thompson v. Economy Super Marts, Inc., 221 Ill. App. 3d 263, 265 (1991). Accordingly, where a business invitee is injured by slipping and falling on defendant’s premises, liability may be imposed if the substance was placed there by the negligence of the proprietor or his servants or, if the substance was on the premises through acts of third persons or there is no showing how it got there, liability may be imposed if the proprietor or his servant knew of its presence or if the substance was there a sufficient length of time so that in the exercise of ordinary care its presence should have been discovered. See Thompson, 221 Ill. App. 3d at 265.
There is also a rule in Illinois known as the natural-accumulation rule. The natural-accumulation rule provides that a landowner does not have a duty to a business invitee to remove natural accumulations of snow and ice. See Watson v. J.C. Penny Co., 237 Ill. App. 3d 976, 978 (1992). Even if the snow and ice remain on the property for an “unreasonable” length of time, it has been held that no liability will be imposed on the proprietor as long as the snow and ice is a natural accumulation. See Foster v. George J. Cyrus & Co., 2 Ill. App. 3d 274, 279 (1971) (where this court rejected a rule that would require property owners to remove natural accumulations of snow and ice after a reasonable length of time or be liable for injuries suffered by their tenants). However, if the snow or ice was produced or accumulated by artificial causes or if the snow or ice was produced or accumulated in an unnatural way because of defendant’s own use of the area, concerned, liability will be imposed. See McCann v. Bethesda Hospital, 80 Ill. App. 3d 544, 548 (1979).
The natural-accumulation rule was first recognized in Illinois by our supreme court in Graham v. City of Chicago, 346 Ill. 638 (1931). In Graham, plaintiff sued the City of Chicago when she slipped and fell on a patch of ice that had formed on a city sidewalk. The Illinois Supreme Court adopted the natural-accumulation rule, holding that it would be “unreasonable to compel a city to expend the money and perform the labor necessary to keep its walks reasonably free from ice and snow during winter months.” Graham, 346 Ill. at 643.
This rule was later extended beyond cities and municipalities to allow landlords to escape liability for injuries incurred by tenants who slipped and fell on naturally accumulated snow and ice while on the landlord’s premises. In Cronin v. Brownlie, 348 Ill. App. 448 (1952), a tenant slipped and fell on a walk that was covered with naturally accumulated snow and ice. This court applied the natural-accumulation rule and stated:
“In our northern climate where ice and snow come frequently and are accepted by all, it appears to us that the [natural-accumulation] rule adopted by the majority of the States finding no liability against the landlord is more reasonable and persuasive ***. *** [I]t appears to us to be unreasonable and somewhat impractical to require a landlord to remove ice and snow from sidewalks used jointly by his tenants where the ice and snow arise from natural causes.” Cronin, 348 Ill. App. at 456.
Since Cronin, Illinois courts have consistently applied the natural-accumulation rule to all types of businesses. Riccitelli v. Sternfeld, 1 Ill. 2d 133 (1953) (natural-accumulation rule applied to path through snow on sidewalk adjoining filling station); Galivan v. Lincolnshire Inn, 147 Ill. App. 3d 228 (1986) (natural-accumulation rule applied to parking lot at an inn); Thompson v. Tormike, Inc., 127 Ill. App. 3d 674 (1984) (natural-accumulation rule applied to parking lot of restaurant); Smalling v. La Salle National Bank, 104 Ill. App. 3d 894 (1982) (natural-accumulation rule applied to parking lot at shopping center); Lohan v. Walgreens Co., 140 Ill. App. 3d 171 (1986) (natural-accumulation rule applied to snow and ice that naturally accumulated outside store but had been tracked inside). In addition, Illinois courts have applied the natural-accumulation rule to all areas on a defendant’s property (i.e., on a sidewalk, on a parking lot, inside a store, or on the step of an entranceway (see Gehrman v. Zajac, 34 Ill. App. 3d 164 (1975) (tenant))). Plaintiffs fail to cite a single case that has created an exception to the natural-accumulation rule on the basis of where the fall occurred or on the basis of what kind of business was being conducted on the property.
In the instant case, plaintiffs request that we not apply the natural-accumulation rule because Kevin slipped and fell on a display area on defendant’s property. Plaintiffs contend that because defendant encourages plaintiffs to go to the display area, defendant should maintain that area as “a safe place for customers to come upon and inspect the automobiles displayed for sale.” Furthermore, plaintiffs contend that because defendant directly benefits from having the display area, it should shoulder the burden of keeping that area safe or close the area in the presence of snow and ice.
In determining whether a duty exists, the court must consider the following factors: (1) the reasonable foreseeability of the injury, (2) the likelihood of injury, (3) the magnitude of the burden of guarding against it, and (4) the consequences of placing that burden upon the defendant. See Maschhoff v. National Super Markets, Inc., 230 Ill. App. 3d 169, 172 (1992). The reason our courts have consistently found that a landowner does not have a duty to keep premises safeguarded against the potential dangers of naturally accumulated snow and ice is because it would be unreasonable in our climate to force a defendant to expend the money and labor necessary to constantly keep the areas safe. See Graham v. City of Chicago, 346 Ill. 638 (1931); Cronin v. Brownlie, 348 Ill. App. 448 (1952). A similar rationale is explained in American Jurisprudence Second
“[I]n a climate where there are frequent snowstorms and sudden changes in temperature, these dangerous conditions appear with a frequency and suddenness which defy prevention, and usually, correction; consequently, the danger from ice and snow in such locations is an obvious one, and the occupier of the premises may expect that an invitee on his premises will discover and realize the danger and protect himself against it.” 62A Am. Jur. 2d Premises Liability § 699 (1990).
Based on the reasons noted above, Illinois courts have consistently determined that no duty exists for a defendant to remove, monitor, or exercise reasonable care in making reasonably safe an area which contains naturally accumulated snow and ice.
In the instant case, we shall not depart from Illinois’s well-established natural-accumulation rule. We believe that defendant owes no duty to plaintiffs to exercise reasonable care toward protecting its outdoor display area from the hazards associated with the natural accumulation of snow and ice. As we have repeatedly noted, in our northern climate, snow and ice can occur frequently and unpredictably. Furthermore, snow and ice are a hazard in this part of the country, and that hazard is known to all. As our courts have consistently found it an unreasonable burden for a business to keep small areas such as parking lots, sidewalks, and entryways safe from naturally accumulated snow and ice, we believe that it would be even more burdensome to require an automobile dealership to monitor its entire display area. Is not almost every automobile that is for sale on defendant’s lot on display? Although plaintiffs fail to describe the dimensions of the display area, common sense tells us that such an automotive display area is normally much larger than an average parking lot, sidewalk, or entryway. Our acceptance of plaintiffs’ request would effectively require all outdoor businesses to constantly monitor their entire business activity area or close their entire business activity area at the first sign of snow or ice. We believe that to place such expense and burden on a property owner is unreasonable.
Therefore, we believe that the natural-accumulation rule is applicable to the instant case. A different result would essentially overrule the natural-accumulation rule. As this court has previously stated, we are not the proper forum in which the natural-accumulation rule should be overruled. See Watson v. J.C. Penny Co., 237 Ill. App. 3d 976, 978-79 (1992) (this court stated that the plaintiff’s request to overrule the natural-accumulation rule should be addressed “to the legislature, which formulates the public policy of this State and which could change this ‘antiquated rule’ if it wished”). Accordingly, the circuit court correctly applied the natural-accumulation rule and properly dismissed plaintiffs’ complaint.
On another matter, on September 30, 1998, we entered an order indicating that we would take with this appeal a motion filed by defendant to strike portions of plaintiffs’ reply brief. For the reasons explained in plaintiffs’ response to the motion to strike, we deny said motion.
For the foregoing reasons, the dismissal by the circuit court of counts IV and V is hereby affirmed.
Affirmed.
RARICK, EJ., concurs.