Cordy v. Sherwin Williams Co., 975 F. Supp. 639, 641 (D.N.J. 1997).
Nunez v. Schneider Nat’l Carriers, 217 F. Supp. 2d 562, 564 (D.N.J. 2002).

Let me be clear that I don't know anything about these cases except that they are cited by "LITIGATING THE INVOLUNTARY DISMOUNT—NUNEZ V. SCHNEIDER NATIONAL CARRIERS AND THE VIABILITY OF A BICYCLE HELMET DEFENSE by Hans N. Huggler

As noted there, "The Note concludes that the bicycle helmet defense is a viable strategy
for reducing a defendant’s damages when an un-helmeted cyclist has
incurred head injuries that could have been prevented through helmet
use. In the 10 jurisdictions whose jurisprudential and legislative environments
make them “target states,” the defense should be a natural extension
of the seatbelt defense, even where the seatbelt defense itself has
been statutorily curtailed. "