Case Analysis – Liebeck V. McDonald’s Restaurants
Case Analysis – Liebeck V. McDonald’s Restaurants
Liebeck v. McDonald’s Restaurant, a case that has popularly been known as the “McDonald Coffee Case”, is a well known legal tussle that took place in the US in 1994. Although many deemed this case as frivolous, the case has changed the look of things in the realm of business law. The plaintiff was one 79-year old woman Stella Liebeck who accidentally spilled the hot coffee she had purchased McDonalds onto her lap sustaining third degree burns. According to legal experts, the coffee was not only hot but also scalding, culpable of dreadful damage to the skin, muscle, or flesh (Meiners, 2012). This paper critically analyzes the case facts, the issues in the case, the decision that the judges took, and the applicable laws from the lens of business law. The paper further seeks to assess various approaches that would have been adopted if necessary, and how the case would have been solved alternatively.
There are several facts in this case. The victim in this case is a woman, 79 –year old by the name Stella Liebeck. She resided in New Mexico and earned a net annual salary of $ 5, 000 as a sales clerk (Cain, 2008). Stella was being driven by her grandson Chris on February 29, 1992, when she bought a glass of coffee at a drive-thru window from a local McDonald’s restaurant. She was served with the coffee in a Styrofoam cup. Chris moved the car away from the drive-thru window and stopped it so she could add sugar and cream to the coffee. However, Ms. Liebeck had trouble removing the lid, thus she placed coffee between her legs, freeing the two hands so that she could remove the lid. When she was removing the lid, the entire cup of coffee spilled over her thighs, immediately Getting absorbed by her sweat suit like she had been submersed in a scalding liquid (Gerlin, 2002). According to Cain (2008), the drink was heated to between 180-190 0F; almost 70 degrees hotter than the recommended average temperatures for coffee. The extreme temperature caused Ms. Liebeck to sustain 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 the moment that accident occurred, Ms. Liebeck as never been able to use or bend her legs to the same way she used to before the accident; her entire lifestyle was adversely affected (Gerlin, 2002). She filed a law suit against McDonald’s that only sought compensation for her medical bills that totaled more than $ 20,000, however, the company refused an out of court settlement but rather insisted on a trial (Cain, 2008).
Main Laws Violated
The applicable law in the hot coffee case will be that of “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 major argument for “product liability” would be that the company was aware but still chose to serve their coffee hot. This way, they should have predicted the possibility that their customers would accidentally get burnt by spilling the hot coffee on themselves.
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 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 unaddressed. 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.
In cases of contributory negligence, the judge decides the amount of money to compensate for the damages imposed on them. However, the credible evidence, the burden of proof, and the combined definition of the negligence must meet the threshold of such a fine.
Choosing the Court System
The McDonald’s hot coffee case was heard in a state court. Initially, the case needed not to go to court, it would have been settled out of court. By demanding compensation for the damage of the hospital bill, Ms. Liebeck was willing to leave it at that. However, the defendant opted to neglect the responsibilities on their side and decided to settle the matter in court. The court requires that the plaintiff provides a truthful case before the judges, with enough evidence to support their claim. The court also requires the defendant to equip themselves with an attestation that is correct and can convince the judges that there is no case before them.
The reasons as why it was necessary for the case to be heard in a state court are as discussed; the plaintiff asked for compensation out of court, for which the defendant thought it was not their fault that the plaintiff sustained injuries, hence opted to settle the case in court. The fact that there were more than 700 prior complaints of coffee burns of varying degrees from mild to 3rd degree reported by customers of McDonald’s coffee shop meant that there was need to investigate the matter at hand because this shows the level of negligence portrayed by the defendant. The idea that both the plaintiff and the defendant were guilty of negligence contributing to the rise of the case, meant that it was necessary to involve the jury in determining the level of negligence and the amount to be charged to each respective party. It is only in court that it would have been agreed upon what the average temperature of consumable coffee is supposed to range from and what temperature would be considered unsafe.
The plaintiff felt that the coffee was defectively manufactured and served in containers that had design defects, this would mean the court had to be involved to determine whether these claims were true or otherwise. The plaintiff felt that the defendant was aware of the dangerous condition of the coffee inherent in serving it at the temperature at which it was sold, that they knew the likely consequences of selling the coffee at such high temperatures but still went ahead and acted with disregard to human safety. The defendant, on the other hand felt that, if the plaintiff was burnt and damaged as alleged, then her injuries were the result of an accident which was not the responsibility of the defendant. The defendant felt that the 3rd degree sustained by the plaintiff may have been exaggerated by her age, this is because the skin of an elderly person is thinner and heals less easily than the skin of a younger individual. The defendant had to move to court to suggest that certain measures could have been use to avoid the severity of the injuries, such as, the plaintiff should have removed her clothes her clothing immediately that served to hold in the heat of the spilled coffee. All these among many other factors, called for the case to be settled in court so as to avoid bias.
Was the Outcome Justified?
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)
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 percent 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. Also, the plaintiff met the necessary criteria to establish liability of negligence against the defendant. Bagley & Savage (2010) 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 plaintiff’s injury and the defendant’s breach”; (4) the “plaintiff suffered an actual loss or injury” (Bagley & Savage, 2010, p.303), and I think the plaintiff’s ability to successfully establish liability of negligence against the defendant was not overlooked by the judge and the jury.
In addition to the tort of negligence, “product liability” is another applicable law to this case that the judge and the jury based their final decision upon, which 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). Since McDonald’s was the seller of this product, and 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 third degree burns, the judge and the jury weighted heavily on the governing law, saw photographs of the plaintiff’s burns before and after skin grafting, and her weight loss, followed by a two year medical treatment; awarded her $2.7 million in punitive damages, which the judge finally reduced to $480,000 for a combined total of $640,000.
The US legal system has numerous checks and balances and control measures in place that deter and penalize frivolous lawsuits and curb excessive jury verdicts Cain (2008). The case elicited numerous strong opinions about the US legal systems, and gave birth to a movement that would reduce the number of lawsuits – the “tort reform” (Meiners et al., 2012), this provided different examples of how the legal processes at times work to protect both the rights of individual plaintiffs as well as the corporations they sue. I strongly believe that in this case, the judge and the jury attentively listened to arguments of the two parties, the plaintiffs and the defendants, reviewed evidence provided at the time of trial, considered all applicable laws governing each case and came to a firm decision in favor of the plaintiff in the “McDonald’s hot coffee case.
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Gerlin, A. (2000). A Matter of Degree: How a Jury decided that a Coffee Spill is worth $2.9 Million. Wall Street Journal. http://www.lectlaw.com/files/cur78.htm
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