I seriously doubt it since it was snowy conditions. To be a criminal action there really must be intent to cause harm, with wintery conditions and only property damage, it would be really hard to put a criminal charge on it... It sucks though, I lost a car by hitting a slab of rock left over by a forklift in the middle of the road, the owner never marked it, he was in his home when I hit it. The officer was a buddy of his, "lost" the photos of the accident and charged me with speeding even though I was going 5 below the limit, his words were "you must have been going way over the speed limit to fly through the air like that and land on the rock." All of which was not true. It was the same color as the road and under a sizable bump, making it pretty impossible to see, barely hit the edge of the wheel on it, but it was around a hundred pounds or so and bent the frame anyway.
Between the improperly written police report, the lost photographs of the accident, and the sudden removal of all the rocks in the area, it was pretty impossible to put a case against the guy.