Yanmar America Corporation v. Randy Nichols

Summary

The court held that Yanmar America voluntarily assumed a duty to warn foreseeable users of gray-market tractors, including Randy Nichols, but that Nichols failed to present substantial evidence that Yanmar America's allegedly inadequate warnings increased his risk of harm. Because the warnings never reached Nichols or the dealer, the risk was no greater than it would have been had Yanmar America undertaken no warning activities, requiring judgment as a matter of law for Yanmar America. Justice Parker questioned whether the increased-risk standard applies to every voluntary-warning situation, and Justice Murdock concurred in the result while questioning whether Yanmar conceded a duty to persons who never received its warnings.