Landlord Didn't Remove Snow and Ice from Sidewalk

DOS issued landlord a violation notice for not removing snow and ice from the sidewalk. The snow had stopped falling two days before the violation was issued. The ALJ fined landlord $50, and he appealed. Landlord argued that he'd tried to clear the sidewalk, but couldn't do so because ice kept forming due to the extremely cold weather. The ECB upheld the fine. Landlord must spread ashes, sand, or other suitable material if he can't clear the ice or snow.

City of New York v. Nyasco Realty: ECB App. No. 21187 (8/10/94) [2-page document]