Liebeck v. McDonald's: The Hot Coffee Case Analyzed

Introduction

In 1994, Liebeck v. McDonald's Restaurants, also referred to as the "McDonald's hot coffee case," became one of the most widely discussed lawsuits in the United States because many considered it frivolous. The case centers on a woman named Stella Liebeck, who spilled hot coffee on her lap after purchasing it from McDonald's. As a result, she suffered third-degree burns and filed suit against the restaurant. Her lawsuit was successful, and she was awarded millions of dollars. The coffee was found to be scalding hot, with the potential to cause serious damage to the skin upon contact (Letric Law, 2011). The major focus of this paper is to critically analyze the McDonald's hot coffee case by examining the stated facts, issues, applicable laws, and decisions made by the judge and jury.

Facts of the Case

Several key facts are associated with Liebeck v. McDonald's Restaurants. Stella Liebeck was a 79-year-old woman from Albuquerque, New Mexico, who earned $5,000 per year as a sales clerk (Cain, 2008). In February 1992, Stella was a passenger in a car driven by her grandson, Chris, who was driving a Ford Probe. Chris drove to McDonald's and purchased a cup of coffee served in a Styrofoam cup (Letric Law, 2011).

After receiving the order at the drive-through window, Chris pulled away and stopped the car so that Ms. Liebeck could add cream and sugar to her coffee. She had difficulty removing the lid, so she placed the Styrofoam cup between her legs, freeing both hands to remove it (Letric Law, 2011). When she attempted to pull off the lid, the entire cup spilled onto her thighs. The hot liquid was immediately absorbed through her sweatpants, as though she had been immersed in scalding liquid (Gerlin, 2002).

The coffee was found to be between 180 and 190 degrees Fahrenheit — approximately 70 degrees hotter than the average cup of coffee. This extreme temperature caused Ms. Liebeck to suffer third-degree burns over 6 percent of her body. She spent more than a week in the hospital and underwent two reconstructive skin graft surgeries, in which skin was taken from one part of her body and grafted onto the burned areas (Cain, 2008). From that point on, Ms. Liebeck was never able to use her legs to the same extent as before, and her overall quality of life was severely diminished (Gerlin, 2002).

Ms. Liebeck initially filed suit against McDonald's seeking only compensation for her medical bills, which totaled more than $20,000. McDonald's refused to settle out of court and insisted on a trial (Cain, 2008).

Legal Issues

The legal issues in Liebeck v. McDonald's Restaurants centered on two primary questions: (1) whether McDonald's was negligent in serving coffee at dangerously high temperatures; and (2) whether McDonald's defective product — the excessively hot coffee — was the proximate cause of the injuries sustained by Ms. Liebeck.

Applicable Laws

The applicable law in this case revolves around three key legal concepts: product liability, the tort of negligence, and contributory and comparative negligence.

According to Bagley and Savage (2010), product liability refers to "the legal liability manufacturers and sellers have for defective products that cause injury to the purchaser, a user or bystander, or their property" (p. 335). The argument for product liability in this case is that McDonald's was aware of the risks associated with serving extremely hot coffee yet chose to continue the practice, and therefore should have foreseen the possibility that customers could be seriously burned. The jury was further surprised to learn that over 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). Product liability applies here because McDonald's was the seller of the product, and the coffee was effectively defective due to its excessive heat. The high temperature presented an unreasonable risk of injury — the very basis of Ms. Liebeck's third-degree burns (Bagley & Savage, 2010, p. 305). Had the product not been defective, Ms. Liebeck might have suffered only a minor first-degree burn.

The tort of negligence is also applicable to this case. Bagley and Savage (2010) define negligence as "conduct that involves an unreasonably great risk of causing injury to another person or damage to property," and it requires that all parties exercise appropriate care in any given situation (p. 303). In this case, McDonald's conduct created an unreasonable risk of harm to Ms. Liebeck. She sustained third-degree burns as a direct result of the restaurant brewing its coffee at temperatures between 180 and 190 degrees Fahrenheit (Gerlin, 2002).

Both contributory negligence and comparative negligence also apply to this case. Under the doctrine of contributory negligence, if a plaintiff is found to be negligent in any way, damages cannot be recovered from the defendant. However, because this doctrine can result in unjust outcomes for plaintiffs, most courts have replaced it with the doctrine of comparative negligence (Bagley & Savage, 2010, p. 308). Under comparative negligence, the plaintiff may recover a proportion of his or her loss corresponding to the defendant's share of fault. This doctrine was directly applicable in Ms. Liebeck's case and formed the basis on which the judge and jury reduced her compensatory damages by 20 percent to reflect her own partial responsibility for the spill. Without this doctrine, a finding of contributory negligence could have left Ms. Liebeck with no compensation at all.

Conclusion

Our legal system has numerous checks and balances and control measures in place that deter frivolous lawsuits and curb excessive jury verdicts (Cain, 2008). Stella Liebeck's lawsuit against McDonald's generated strong opinions on both sides of a heated debate about America's legal system, and it helped give rise to a movement to reduce the volume of lawsuits and cap jury awards — commonly known as tort reform (Lexis-Nexis, 2008). The case provided a concrete example of how legal processes can work to protect the rights of individual plaintiffs as well as the corporations they sue.