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Bell Sports, Inc. v. Yarusso

Delaware Supreme Court
759 A.2d 582 (2000)


Brian Yarusso (plaintiff) was rendered a quadriplegic after crashing his off-road motorcycle. Yarusso sued Bell Sports, Inc. (Bell) (defendant), the manufacturer of the helmet that Yarusso was wearing at the time of the accident, claiming that his injuries were the result of a defect in the design of the helmet. Yarusso brought claims for negligence, breach of express warranties, and breach of the implied warranty of merchantability. The introduction section of the helmet’s owner’s manual stated that “the primary function of a helmet is to reduce the harmful effects of a blow to the head.” The helmet performance section of the manual stated that the helmet “is designed to absorb the force of a blow by spreading it over as wide an area of the outer shell as possible.” The owner’s manual also contained a five-year limited warranty. That section of the manual stated that the five-year warranty was expressly in lieu of all other warranties. The jury found that Bell had breached express warranties or, alternatively, implied warranties, but was not negligent, and awarded Yarusso damages. The Superior Court denied Bell’s motions for judgment as a matter of law and for a new trial. Bell appealed.

Rule of Law


Holding and Reasoning (Walsh, J.)

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