Liebeck v. McDonald's Restaurants, P.T.S., Inc. and McDonald's International, Inc., No. CV-93-02419 (Second Judicial District Court, Bernalillo County, New Mexico, 1994)
The jury finds that plaintiff Stella Liebeck (aged 79) sustained injuries as a result of defendant McDonald's Restaurants, P.T.S., Inc.'s defective product and failure to warn of the dangerously high serving temperature of its coffee. Compensatory damages are assessed at 200,000 USD, reduced by 20% for the plaintiff's comparative fault to 160,000 USD. Punitive damages are assessed at 2,700,000 USD — an amount equivalent to approximately two days of McDonald's global coffee sales. The trial court (Hon. Robert H. Scott) thereafter remits the punitive damages to 480,000 USD (three times the compensatory damages), yielding a final judgment of approximately 640,000 USD. During McDonald's appeal, the parties reach a confidential settlement in or about November 1994, the terms of which remain sealed.
Liebeck v. McDonald's Restaurants is simultaneously the most famous and the most thoroughly misunderstood tort case in modern American legal history. The underlying incident occurred on 27 February 1992 when Stella Liebeck, a 79-year-old retired department store clerk, purchased a 49-cent medium cup of coffee from an Albuquerque McDonald's drive-through while her grandson Chris drove her 1989 Ford Probe. Chris pulled the car into a parking stall and stopped so that Stella could add cream and sugar. She placed the styrofoam cup between her knees and attempted to pry off the lid. The entire cup tipped toward her, spilling approximately 170 ml of near-boiling coffee into her cotton sweatpants, which absorbed the liquid and held it against her skin for roughly 90 seconds before her grandson could help her out of the pants. Liebeck suffered full-thickness (third-degree) burns over 6% of her total body surface area — including her inner thighs, perineum, buttocks, and genitalia — and partial-thickness (second-degree) burns over a further 16%. She was hospitalised for eight days, underwent multiple debridement procedures and skin-graft surgeries, lost approximately 20 pounds during recovery (down from an already slight frame), and required two years of convalescence and periodic medical follow-up. Her medical bills totalled approximately 11,000 USD. Liebeck's initial letter to McDonald's sought only coverage of her out-of-pocket medical expenses and approximately 20,000 USD to compensate her daughter for lost income during the period she stayed home to provide care; McDonald's offered 800 USD. After this refusal, she retained Houston products-liability attorney S. Reed Morgan and filed suit in the Second Judicial District Court of New Mexico. Discovery disclosed the facts that transformed the case. McDonald's operations manual required franchisees to hold coffee at 180–190°F (82–88°C) at the point of service — substantially hotter than the 135–150°F typical of home drip coffee makers and 20–30°F hotter than most competitors. McDonald's quality-assurance manager Christopher Appleton testified that the company was aware the coffee caused severe burns, that it had received more than 700 reports of coffee burns between 1982 and 1992 (including children and multiple third-degree burns), that it had paid at least 500,000 USD in prior settlements, and that it had never considered lowering the serving temperature. Internal documents described coffee at this temperature as "not fit for consumption" because it would burn the mouth and throat; McDonald's served it that hot because its marketing research indicated that coffee odour and the perception of freshness were maximised at higher temperatures, and because most customers were commuters who would drink the coffee after their drive to work. Medical expert Dr Charles Baxter testified that liquid at 180°F will produce third-degree burns in 12–15 seconds of skin contact; at 155°F the same burn requires roughly 60 seconds — enough time for reflexive reaction. Morgan proposed that McDonald's lower its serving temperature to 160°F; McDonald's refused. The jury, after a seven-day trial before Judge Robert H. Scott and roughly four hours of deliberation on 17–18 August 1994, returned a verdict finding McDonald's liable on five theories (defect, failure to warn, breach of implied warranty, and two others); assigned 80% comparative fault to McDonald's and 20% to Liebeck; awarded 200,000 USD in compensatory damages (reduced by comparative-fault percentage to 160,000 USD); and awarded 2,700,000 USD in punitive damages, an amount calculated to equal approximately two days of McDonald's global coffee revenues. The trial court subsequently exercised its remittitur authority to reduce the punitive award to 480,000 USD (three times compensatory damages, a traditional benchmark), yielding a final judgment of approximately 640,000 USD. McDonald's noticed an appeal; the parties settled confidentially in or about November 1994 under a non-disclosure agreement whose terms remain sealed. The case's long shadow operates on at least four levels. JURISPRUDENTIAL: Liebeck is a canonical application of products-liability doctrine — particularly the consumer-expectations test for design defect, the duty to warn of known dangers, and the use of a defendant's wealth and prior knowledge of harm in calibrating punitive damages under BMW of North America, Inc. v. Gore (1996) and State Farm Mutual Automobile Insurance Co. v. Campbell (2003), both of which cite Liebeck-style reasoning. REGULATORY: It remains the paradigmatic illustration of punitive damages functioning as private-regulatory tort — where civil juries enforce safety standards that regulators have not imposed. Within two years of the verdict, McDonald's reduced its coffee serving temperature to approximately 158–176°F and redesigned its lids and cups with more prominent warnings; the industry as a whole recalibrated hot-beverage safety norms. POLITICAL: The case became the centrepiece of the 1990s "tort reform" movement, invoked in U.S. Chamber of Commerce and American Tort Reform Association campaigns to enact state-law caps on punitive damages and other plaintiff-unfriendly reforms, and repeatedly cited by legislators from President Reagan onward as exemplary of "frivolous litigation." The popular narrative — an elderly woman spilled coffee on herself and won millions — entered political rhetoric, stand-up comedy (Seinfeld's "The Maestro" episode, 1995), and became a cultural shorthand for litigation abuse. SOCIO-LEGAL: Susan Saladoff's 2011 HBO documentary "Hot Coffee" (executive-produced by Sheila Nevins) comprehensively revisited the case, exposing the gulf between the sensationalised public account and the actual evidentiary record: the severity of Liebeck's injuries, McDonald's prior knowledge of more than 700 burn incidents, its rejection of a modest temperature reduction, and the jury's calibrated analysis. The documentary has become required viewing in many U.S. law-school torts courses. Liebeck herself, who died in 2004 at age 91, never fully recovered and lived with chronic pain and disfigurement for the remaining decade of her life. The case endures as a teaching example of how litigation records and media narratives can systematically diverge — and how the resulting distortion can reshape public opinion, legislative policy, and doctrinal development for decades.
Judge
Robert H. Scott
Prosecutor
Kenneth R. Wagner, Tracy McGee
Defense
S. Reed Morgan, Kenneth R. Wagner
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