This is a mechanism by which a few people die each year. A person ends up upside down in a tree well, almost always on a snowboard, which they cannot get out of. The snow is soft, and they can get no purchase, and exhaust themselves, but as they flail, work themselves deeper, and basically drown. Typically the snowboard is found sticking out. Doesn't happen with skis, because you can pop out of them, but you have to reach up to get out of the board, and the snow blocks this.
I don't much like trees in snow since my skull fracture and brain bleed in a collision with one. (Squaw Valley)
The tree won.
