INTRODUCTION
The infamous ‘hot coffee case’ definitely brought about a revolution in the field of Torts Law. The case was often termed as a ‘frivolous lawsuit’, however a close look at the intricacies of the case would prove otherwise. Stella Liebeck, an a-79-year-old woman was waiting with her grandson in the McDonald’s (Albuquerque, New Mexico) drive-through. Liebeck had ordered a hot coffee for herself. McDonald’s served the coffee in a Styrofoam cup. Owing to the lack of cup holders in the car her grandson decided to pull up the car in the parking lot. In an attempt to open the lid of the cup, Liebeck spilt the hot coffee onto her lap. The rumours of Liebeck spilling her coffee while driving were inaccurate. The car was not moving, and she was not driving[1]. The coffee was estimated to be somewhere between 180 to 190 degrees[2]. One can infer from the aforementioned fact that coffee was ‘dangerously hot’. Experts agree that these temperatures are more than enough to induce this sort of damage in less than a second[3]. Furthermore, Liebeck wore sweatpants that soaked up the coffee and held it against her skin. A vascular surgeon confirmed that Liebeck suffered from third-degree burns (the most severe kind) that required immediate hospitalization and skin grafting. As a result of this tragedy, Liebeck was rendered permanently disfigured. Initially, Liebeck asked for a compensation of $11,000 from the chain. Subsequently, when McDonald’s refused to entertain her claims, she hired an attorney who had previously argued a similar case (in 1986) for a woman who had suffered third-degree burns due to the McDonald’s coffee. In the 1986 case, a McDonald’s quality assurance manager testified that “he was aware of the risk and he had no plans to turn down the heat”[4]. It is also important to note that Liebeck’s case was no isolated incident, 700 such accidents (1982-1992) due to the coffee spill were reported out of which a few were settled. Another offer was made by Liebeck wherein she offered to settle the case at $ 20,000 but McDonald’s never offered more than $800 and hence the matter went to trial.
ARGUMENTS BY THE PARTIES
Following are the primary arguments made by the plaintiff:
- Whether the chain was aware of the fact that selling coffee at 180-190 degrees was hazardous.
- Whether customers who have attempted to drink dangerously hot coffee have experienced burns in their throat.
- Whether adequate measures and quality cups were used while serving such a hot coffee.
- Whether any attempts after the 1986 case were made to lower the temperature of the coffee.
As the trial progressed, shocking revelations emerged. The chain expressed that it was well aware of the fact that the coffee was served at such a high temperature and it had the capacity to cause severe and even third-degree burns. However, in order to maintain the ‘optimal taste’ which resulted in sales of billions of coffee cups they turned a deaf ear towards such complaints. McDonald’s expert testified the same. Had the coffee been served at 160 degrees Liebeck would have gotten 20 seconds buffer time wherein instantaneous damage could have been avoided. At the trial, Mc Donald’s argued that consumers wanted “steaming hot coffee”. The chain’s consumer indifference became evident when despite being aware of the previous cases of coffee burns and such injuries no changes were made in the temperature or the manner in which it was served. McDonald’s argued that Liebeck majorly contributed to her injury primarily because she placed the cup between her knees while attempting to open the lid and that she did not remove her clothing promptly after the spill. Additionally, they also argued that Liebeck’s burns worsened due to the fragility of her skin (owing to her old age).
JUDGEMENT
The hearing continued for almost a week. The court held McDonald’s was liable on the claims of product defect, breach of the implied warranty of merchantability, and breach of the implied warranty of fitness for a particular purpose[5]. However, applying the principles of contributory negligence the original compensation of $200,000 was cut down by 20% to $160,000. $2.7 million were awarded for the punitive damages. The amount arrived on the basis of McDonald’s coffee revenue earned per day (i.e., $1.34 million). These overall exemplary damages constituted about two days’ revenue earned from the sales of coffee alone. That wasn’t, however, the end of it. The original punitive damage award was ultimately reduced by more than 80 percent by the judge[6]. In order to avoid more hassles, both parties reached a confidential agreement.
CONCLUSION
The case has often been termed as “a frivolous litigation”, “jackpot justice”, “the poster child of excessive lawsuits” [7]not only by the common man but also by renowned personalities and news channels. As the case made headlines, talk show storylines, and punchlines one thing that was lost was the facts. However, Mrs Liebeck had a substantial case and she brought to light the Chain’s indifference towards its very own customers. Moreover, the intensity of the burns that resulted due to the spill was extremely high. The spill resulted in third-degree burns, something which is not usual or acceptable. It is evident that McDonald’s was more concerned about selling coffees than responding to complaints. It was necessary to discourage such practices. Regard should also be given to the fact that the punitive damages were substantially reduced and negligence on the part of Liebeck was also taken into consideration. Had it been a facetious issue the case would have been dismissed. Various eminent jurors lauded the decision of the court that drove the chain to add precautionary instructions on the cup and bring the temperature down in order to avoid it. However, the condensed narration of the story distorted its facts and created a wrong perception in the minds of people at large.
Author(s) Name: Anaya Nandish Shah (Gujarat National Law University, Gandhinagar)
