Products Liability — Warning Content Relevant to Risk-Utility Analysis

Yamaha Motor Manufacturing Corporation of America v. Hall, No. A26A0228, 2026 WL 1828143, __ S.E.2d __ (Ga. Ct. App. June 22, 2026). The court (McFadden, P.J.; Watkins and Padgett, JJ., concur) reverses the judgment entered on a $7 million jury verdict in a golf cart rollover case. The court held that the trial court erred by excluding the specific content of the manufacturer's warning labels and operator's manual. Under Georgia's risk-utility analysis for design-defect claims, the jury may consider the avoidability of the danger, the user's knowledge, and the efficacy of warnings. Excluding warning content deprived the jury of evidence relevant to a core issue. Ms.** 2–4. The court also held that the manufacturer preserved the issue by arguing the warnings were relevant to whether the product was defective, even without using the phrase "risk-utility analysis." Ms.** 2–6.

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