The Supreme Court of Pennsylvania has held that harm resulting from the raising of a snow swirl by a bus passing at high speed is not the product of a foreseeable risk or hazard which could render this conduct negligent.
Metts v. Griglak, 438 Pa. 392, 264 A.2d 684 (1970).
J. S. Kreglow,
Torts - Negligence - Causation - Foreseeability,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol9/iss3/16