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Baughn v. Honda Motor Company
Washington Supreme Court
727 P.2d 655 (1986)
Douglas Bratz and Bradley Baughn, both about age nine, ignored three stop signs and collided with a truck while riding a Honda Motor Company (defendant) mini-trail bike on a public road. Mr. Bratz and Mr. Baughn (plaintiff) both had their own motorcycles and had purchased multiple mini-trail bikes for their children. Both fathers told their children not to ride their mini-trail bikes in the street. Mr. Baughn took Bradley’s bike away for riding it in the street. Mrs. Bratz saw Douglas and Bradley riding in the street but did not stop them. A decal on the mini-trail bike instructed that it was manufactured for off-the-road use only and to always wear a helmet. There was also a warning label on top of the gas tank that said to read the owner’s manual and that the bike was for off-the-road use only and not for public streets. The first page of the owner’s manual stated in bold print that the bike was for off-the-road use only and that it was important for parents to review the manual with their children. Mr. Baughn and Mr. Bratz argued the warnings were inadequate because they did not describe what might happen if a child rode in the street, and that a special duty to warn is owed if a manufacturer markets an item for children. They also criticized Honda for failing to advise parents how to determine whether their child was ready to ride a mini-trail bike. The trial court ruled that Honda satisfied its duty to warn under the law of negligence and strict liability. Mr. Baughn appealed.
Rule of Law
Holding and Reasoning (Andersen, J.)
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