instructions regarding negligence and the negligence of a property owner. See Wis JI&emdash;Civil 1005, 8020. 6 Children under age 18 are required to wear helmets when riding an ATV See Wis. Stat. § 23.33(3g)(a). 7 See U.S. Consumer Product Safety Commission CPSP Document #540, http://www.cpsc.gov; State of Wisconsin, Department of Natural Resources, Accident Reporting and Statistics, http://www.dnr.state.wi.us; Wisconsin Briefs, Motorcycle Safety, LRB-9L-WB-2 (February 1994); and, U.S. Department of Transportation, Nat'l Highway Traffic Safety Adm., Motorcycle Helmet Use Laws, http://www.nhsta.dot.gov. 8 Courts in other jurisdictions are split on the issue of the helmet defense. See e.g,, cases allowing the helmet defense: Rodgers v. American Honda Motor Co., 46 F.3d 1 (1st Cir. 1995) (<HOLDING>); Dailey v. Honda Motor Co., 882 F.Supp. 826
holding plaintiff could not recover on nuisance action to recover for alleged damage to property he does not own or rent holding that the plaintiff was not barred by hrs  3865 from seeking common law tort remedies against his insurer for injuries caused by the insurers  outrageous and intentional denial of medical benefits and disability payments  because such injuries were not  work injuries  within the scope of hrs chapter 386 holding that the plaintiff could not recover when his failure to wear a helmet caused essentially all of his injuries holding that where a prior agreement fixed the salary of the plaintiff plaintiff could not seek to recover for his services on a theory of unjust enrichment recognizing that where a plaintiff failed to perform because of the defendants breach the plaintiff could recover damages caused by the defendants breach