It is possible for a Snow Golem to be naturally generated in an Ice Plains Spikes biome due to the changes made in the 1.8.1 update. This being that Snow Golems can now generate sideways. Snow blocks naturally generate across the surface of the biome and if a pumpkin was to generate next to two horizontal snow blocks then a Snow Golem will naturally spawn.
This is evident in the seed -8194753951739883801 where if you travel to the co-ordiantes x= 995400 y= 72 z= 97344 a Snow Golem will spawn next to a Lake structure.
Note: Teleporting direct to 995400 72 97344 will not work as for some reason the terrain generates differently after doing so. In order to guarantee finding the snow golem you must teleport somewhere where the co-ordiantes 995400 72 97344 are out of range of your render distance. For example if you were using two chunks as your render distance you could teleport to 995300 72 97344 and then travel to 995400 72 97344 and the Snow Golem will spawn.