Yamaha Motor Corp., U.S.A. v. McTaggart

720 S.E.2d 217, 313 Ga. App. 103, 2011 Fulton County D. Rep. 3720, 2011 Ga. App. LEXIS 1011
CourtCourt of Appeals of Georgia
DecidedNovember 15, 2011
DocketA11A1022
StatusPublished
Cited by4 cases

This text of 720 S.E.2d 217 (Yamaha Motor Corp., U.S.A. v. McTaggart) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Yamaha Motor Corp., U.S.A. v. McTaggart, 720 S.E.2d 217, 313 Ga. App. 103, 2011 Fulton County D. Rep. 3720, 2011 Ga. App. LEXIS 1011 (Ga. Ct. App. 2011).

Opinion

Doyle, Judge.

Roger and Glenda McTaggart filed a personal injury action against Yamaha Motor Corporation, U.S.A., Yamaha Motor Manufacturing Corporation of America, and Yamaha Motor Company, Ltd. (collectively, “Yamaha”), after Roger sustained injuries when his Yamaha Rhino1 rolled over onto his leg.2 The McTaggarts’ sole claim at trial was that the Rhino was defective because it lacked a door. At the conclusion of the trial, the jury returned a verdict in favor of the McTaggarts in the amount of $317,002. Yamaha appeals the trial court’s denial of its subsequent motion for new trial, arguing that the trial court erred (1) by denying its motions for directed verdict and judgment notwithstanding the verdict; (2) in its instructions to the jury; and (3) by denying its request to include Yamaha’s [104]*104affirmative defenses on the special verdict form. Because the evidence demands a finding that Roger assumed the risk of his injuries, we reverse and remand the case.

On appeal from a trial court’s rulings on motions for directed verdict and judgment notwithstanding the verdict, we review and resolve the evidence and any doubts or ambiguities in favor of the verdict; directed verdicts and judgments notwithstanding the verdict are not proper unless there is no conflict in the evidence as to any material issue and the evidence introduced, with all reasonable deductions therefrom, demands a certain verdict.3

Viewed in this light, the record shows that the McTaggarts purchased their 2006 Yamaha Rhino 660 in October 2006. The vehicle is a two-seater without doors or windows. It has a steel roof cage, a textured, slip-resistant floor board, foot guards on both sides to help keep feet and legs inside the vehicle, hip guards, handholds, bucket seats, and three-point seatbelts. The vehicle also contains a warning sticker inside the vehicle, which sticker warns users that they could be severely injured or die if they attempt to stop a rollover using an arm or a leg, and it instructs the occupants to keep their arms and legs inside the vehicle.

When Roger purchased his Rhino, the dealership offered to install a flexible, plastic, aftermarket weather enclosure for the vehicle, but Roger explicitly declined because he preferred open access to allow for easy ingress and egress. In July 2007, following Roger’s injuries, Yamaha added sculpted doors on new Rhinos and offered to install them on pre-owned vehicles after learning of lower extremity injuries that occurred when drivers extended their legs outside the vehicle during rollovers.

Roger traversed a variety of terrains in the Rhino at his property in Blue Ridge, Georgia, and he used the vehicle to haul dirt and livestock feed, build a fence, and carry equipment for his job as a grave digger. On May 14, 2007, Roger entered his Rhino, turned off the emergency brake, and put the vehicle into gear. According to Roger, he applied slight pressure to the gas pedal while making a “slight right turn,” and the vehicle flipped over onto the driver’s side after traveling less than six feet, landing on Roger’s left leg and causing a severe laceration.

The McTaggarts filed suit in November 2008, asserting claims for negligence and strict liability. The complaint alleged that Roger’s [105]*105injuries were caused by a latent stability defect and the absence of doors. Four weeks before trial, the McTaggarts abandoned their stability defect claims, electing to proceed solely on their claim that the Rhino’s occupant compartment was defective because it did not have a door.4

The jury returned a verdict in favor of the McTaggarts as follows: $140,000 for pain and suffering; $13,690 for medical expenses; $38,312 for lost wages; $100,000 for future lost wages; and $25,000 for Glenda’s loss of consortium.5 Yamaha subsequently filed a motion for new trial, which the trial court denied, and this appeal followed.

1. Yamaha argues that the trial court erred by denying its motions for a directed verdict and judgment notwithstanding the verdict because the undisputed evidence at trial demanded a finding that Roger assumed the risk of his injuries. We agree.

“Assumption of risk means the plaintiff is fully aware of the dangerous defect or condition caused by defendant’s negligence but freely chooses to proceed nonetheless.”6 Therefore, a plaintiffs recovery for an injury caused by a defective product is precluded under the affirmative defense of assumption of the risk if the defendant proves that the plaintiff “without coercion of circumstances, chooses a course of action with full knowledge of its danger and while exercising a free choice as to whether to engage in the act or not.”7 “In asserting a defense of assumption of the risk, a defendant must establish that the plaintiff (1) had actual knowledge of the danger; (2) understood and appreciated the risks associated with such danger; and (3) voluntarily exposed himself to those risks.”8

Knowledge of the risk is the watchword of assumption of risk, and means both actual and subjective knowledge on the plaintiffs part. The knowledge that a plaintiff who assumes a risk must subjectively possess is that of the specific, particular risk of harm associated with the activity or condition that proximately causes injury. The knowledge requirement does not refer to a plaintiff’s comprehension of [106]*106general, non-specific risks that might be associated with such conditions or activities.9

Finally, “[ajlthough assumption of the risk is ordinarily a jury question, in plain, palpable, and indisputable cases resolution of the issue by a jury is not required.”10

Here, the jury found that the Rhino’s defective design proximately caused Roger’s injuries, and Yamaha does not appeal this portion of the verdict.11 Regardless, if Yamaha established that Roger assumed the risks associated with operating the doorless vehicle, then Roger cannot recover. Construed in favor of the verdict, we conclude that Yamaha demonstrated that Roger had actual and subjective knowledge of the specific danger associated with the doorless design of the Rhino, that he fully appreciated the risks associated therewith, and that he voluntarily exposed himself to those risks.

Roger initially planned to purchase an all-terrain vehicle (“ATV”), but changed his mind at the dealership when he saw the doorless Rhino because “given [his] size, it would be easy to get in and out of,” and “[i]t would let [him] get in and out of the vehicle easily so that [he] wouldn’t have to step over the seat like [he] would in an ATV” Roger agreed at trial that the Rhino was useful to him specifically “because it had no door.”

Roger also testified that he understood the warnings and instructions posted on the vehicle, which directed occupants to keep their limbs inside the vehicle at all times, and that he read the operator’s manual:

Q: . . . Let’s talk about the operator’s manual. You read that manual when you got the vehicle, correct?
A: Correct. . . .
Q: So you got the chance to read the manual, including the safety warnings about not using too much speed or too much steering, correct?

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720 S.E.2d 217, 313 Ga. App. 103, 2011 Fulton County D. Rep. 3720, 2011 Ga. App. LEXIS 1011, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yamaha-motor-corp-usa-v-mctaggart-gactapp-2011.