Forsberg v. Volkswagen of America, Inc., 769 F.Supp. 33 (1990)
'The vast majority of high state courts and state legislatures that have considered the issue have concluded that evidence of the nonuse of seat belts is not admissible for the purpose of proving plaintiffs' negligence. ... Courts in the majority have reasoned that where a plaintiff's failure to wear a seat belt merely adds to injuries caused by a car accident, without contributing to the happening of the accident, the nonuse of the seat belt is not negligence. ... There is no indication that New Hampshire law permits the admission of seat belt evidence to prove comparative negligence. To the contrary, both New Hampshire statutory and common law suggest that such evidence is not admissible for this purpose, and this view is consistent with the clear trend in other jurisdictions. Therefore, this Court concludes that New Hampshire would follow the majority view.'