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Liebeck v. McDonald's Restaurants

1995 WL 360309 (1994)

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Liebeck v. McDonald’s Restaurants

New Mexico District Court

1995 WL 360309 (1994)

Facts

Seventy-nine-year-old Stella Liebeck (plaintiff) went to a McDonald’s Restaurants (defendant) drive-through with her grandson and ordered a cup of coffee. The coffee spilled in Liebeck’s lap, causing severe third-degree burns over 16 percent of her body. The burns required skin grafts, eight days in the hospital, and two years of medical treatment. Liebeck asked McDonald’s for $20,000 to cover her costs, but McDonald’s offered her only $800. Liebeck hired an attorney and brought a defective-products-liability lawsuit, asserting the coffee was too hot and that McDonald’s should have warned customers about the risk of burns. McDonald’s had a written policy requiring its restaurants to serve coffee at 180°F to 190°F, about 20°F hotter than competitors’. Both sides hired experts who debated the reasonableness of that temperature. The testimony showed that at 190°F, coffee can produce third-degree burns in under three seconds. At 180°F, it takes 12 to 15 seconds. At 160°F, it takes a full 20 seconds. More than 700 people, including children, had suffered burns from the coffee in the preceding 10 years, with McDonald’s settling claims for more than $500,000. A McDonald’s expert played down the number of burns by pointing it was a small percentage of millions of cups of coffee served and blamed Liebeck for spilling her coffee. Liebeck’s experts countered that the coffee was not fit for consumption as served. Her doctor testified she had one of the worst scald burns he had ever seen, and the jury saw graphic, compelling photographs of her injuries. The jury awarded Liebeck $200,000 in compensatory damages but found her 20 percent at fault, meaning she could recover $160,000. The jury also awarded Liebeck close to $3 million in punitive damages. Although New Mexico law has no specific cap on recoverable punitive damages, after trial the judge reduced the punitive damages to $480,000 (triple the compensatory award) for a total award of $640,000. The judge denied McDonald’s request for a new trial, and McDonald’s appealed.

Rule of Law

Issue

Holding and Reasoning

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