In 1994, Liebeck v. McDonald's Restaurant, also referred to as the "McDonald coffee case," was a popular case in the U.S. because it was considered frivolous. The case centers around a woman by the name of Stella Liebeck, who spilled hot coffee on her lap which she purchased from McDonald's. As a result, she suffered from third degree burns and decided to sue the restaurant for her third degree burns. Her lawsuit was granted and she gained millions of dollars from the case. The coffee was scalding hot and had the potential to cause serious damage to the skin if exposed to it (Letric Law, 2011). The major focus of this paper will be to critically analyze the McDonald coffee case on the stated facts, issues, applicable laws, and decisions made by the judge and jury.
What are the facts?
Associated with Liebeck v. McDonald's case are several facts. Stella Liebeck was a 79-year-old from Albuquerque, New Mexico. She made $5,000.00 a year as a sales clerk (Cain, 2008). In 1992, Stella was seated as a passenger in the car of her grandson Chris on the twenty-ninth day of February. The owner of the car, Chris, was driving a Ford Probe. Chris drives to McDonald's to purchase a cup of coffee which was served in a Styrofoam cup (Letric Law, 2011). Once the order was completed, Chris drives away from the drive-thru window, and stops the car so Ms. Liebeck could add cream and sugar to her coffee. However, she had trouble getting off the lid. She then placed the styrofoam cup between her legs, thus freeing her two hands in order to be able to remove the lid (Letric Law, 2011). When she proceeded to remove the lid while holding the cup between her legs, the entire cup spilled onto her thighs (through her sweatpants) and was immediately absorbed through her sweat suit as if she was immersed in scalding liquid (Gerlin, 2002). The beverage was found to be at a temperature between 180-190 degrees Fahrenheit, about 70 degrees hotter than the average cup of coffee. This extreme temperature resulted in Ms. Liebeck suffering third-degree burns over 6% of her 79-year-old body, and having to spend over a week in the hospital; undergoing two reconstructive (not cosmetic) skin grafts, where skin was shaved from one part of her body and placed on top of the burned areas (Cain, 2008). From that moment on, Ms. Liebeck was never able to bend or use her legs to the same extent as previously, and the overall quality of her life was severely affected (Gerlin, 2002). Ms. Liebeck filed suit against McDonald only seeking compensation for the cost of her medical bills, which totaled more than $20,000, and McDonald refused to settle out of court and insisted on a trial (Cain 2008).
What are the issues?
The issues in the lawsuit of Ms. Liebeck v. McDonald's Restaurants would include (1) if McDonald's been negligent by serving hot coffee to its customers?; and (2) if McDonald's defective product "the hot coffee" was the cause of the injury sustained by Ms. Liesbeck?
What law applies?
The applicable law in the hot coffee case will evolve around "product liability," the "tort of negligence," and the "contributory and the comparative negligence." According to Bagley & Savage, the definition of "product liability" is the "legal liability manufactures and sellers have for defective products that cause injury to the purchaser, a user or bystander, or their property" (Bagley & Savage, 2010, p.335). The argument for "product liability" is that McDonald's was aware but still choose to serve their coffee hot and therefore should have foreseen the possibility that their customers could accidentally get burn by spilling the hot coffee on themselves. The jury was further surprised to learned that during the prior ten years, McDonald's had received more than 700 reports of coffee burns ranging from mild to third-degree, and had settled burn claims for amounts up to and exceeding $500,000 (Lexis-Nexis, 2008). I believe that this law applies to the hot coffee case since McDonald's was the seller of this product. The coffee was manufactured "defectively" due to excessive heat; the high temperature of the coffee presented an unreasonable risk of injury, which indeed was the basis of Ms. Liebeck sustaining a third degree burns (Bagley & Savage, 2010, p.305). . If the McDonald's product was not defective, Ms. Liebeck might have just suffered a first degree burn, without much damage to her skin.
The "tort of negligence" is also applicable to this case because according to Bagley & Savage, "negligence" is defined as "conduct that involves an unreasonably great risk of causing injury to another person or damage to property," and it also requires that "all parties take appropriate care in any given situation" (Bagley & Savage, 2010, p.303). In this case, it is evident that the defendant's conduct created an unreasonable risk of harm to the plaintiff. She sustained a third degree burns due to McDonald's negligence of brewing its coffee between 180 to 190 degree Fahrenheit (Gerlin, 2002).
In addition to above, both the contributory and the comparative negligence applied to this McDonald's hot coffee case. According the Bagley & Savage, under the doctrine of "contributory negligence" if the plaintiff is also negligent in any manner, damages cannot be recovered from the defendant; and the plaintiff's injury would go unredressed. Thus, in order to address the injustice to the plaintiff, most courts have replaced the doctrine of contributory negligence with that of comparative negligence (Bagley & Savage, 2010, p.308). Also, under the doctrine of comparative negligence, the plaintiff may recover the proportion of his or her loss attributed to the defendant's negligence. The law of comparative negligence is applicable to this law and that was the basis the judge and the jury decided to reduce the compensatory damages awarded to Ms. Liebeck by the 20% of her fault. Otherwise, she could have left the court room devastated by the verdict.
What did the judge and/or the jury decides?
In the "hot coffee case," after the arguments and evidence were heard, the six men and six women jury decided on compensatory damages of $200,000 for her medical costs and disability, which they later reduced to $160,000 because the jury determined that 20% of the fault belonged with Mrs. Liebeck, since she spilled the coffee on herself (Cain, 2008). In addition, the jury found that the defendant, McDonald's had engaged in willful, reckless, and malicious conduct, which also constituted the basis for punitive damages, and resulted in the jury awarding the plaintiff, Ms. Liebeck, a $2.7 million in punitive damages. The jury arrived at this amount based on the plaintiff's attorney, Reed Morgan's suggestion to penalize McDonald's for the equivalent of one to two days of companywide coffee sales, which was estimated at $1.35 million a day (Gerlim, 2002). However, the judge reduced the $2.7 million in punitive damages to $480,000, which is three times the compensatory amount, and for a grand total of $640,000. Besides, the verdict was appealed by both parties in December of 1994 and was later settled out of court for an undisclosed amount of money (Letric Law, 2011)
Did the judge and/or the jury make an appropriate decision based on the applicable law controlling the case? Why or why not?
Yes, the judge and the jury made an appropriate decision based on the applicable law controlling the case of Liebeck v. McDonald's Restaurants. The judge and the jury followed all applicable laws governing this case in making their final decision as to who is guilty and not, and how much the plaintiff should be awarded in both compensatory and punitive damages. The compensatory damages of $200,000 awarded to the plaintiff were fair compared to the third degree burns she sustained. However, the application of the comparative negligence doctrine also helped relieve the burden on both the plaintiff and the defendant; great for the plaintiff because if the jury should adopt the doctrine of contributory negligence, Ms. Liebeck would have been awarded zero dollars in compensatory damages; and also great for the defendant because it reduces its liability by the 20% deducted from the initial $200,000, which came to $160,000 in compensatory damages.
Furthermore, the judge and the jury appropriately applied the tort of "negligence" to this case; Bagley & Savage states that it is a "conduct that involves an unreasonably great risk of causing injury to another person or damage to property" (Bagley & Savage, 2010, p.303). Also, the plaintiff met the necessary criteria to establish liability of negligence against the defendant. (Bagley & Savage further explained that the plaintiff must show the following before liability could be established for negligence: (1) that the "defendant owed a duty to the plaintiff to act in conformity with a certain standard of conduct, to act reasonably under the circumstances"; (2) the "defendant breached that duty by failing to confirm to the standard"; (3) a "reasonably close causal connection exists between the…