The Illinois Snow and Ice Removal Act provides immunity for negligent shoveling and de-icing that causes an accident by creating an unnatural accumulation. But on the related question of whether this immunity extends to design defects that cause unnatural accumulations, the score is 3-1 in the tally of opinions from the Illinois Appellate Court.Agreeing with 2013 and 2015 rulings from the appellate court’s 4th and 1st Districts — and rejecting the analysis of a 2014 decision from the 2nd District — a new …