The 1994 verdict in Liebeck v. McDonald's Restaurants emerged as one of the most consequential product liability cases in American legal history. A New Mexico jury awarded Stella Liebeck $2.86 million after she suffered third-degree burns from McDonald's coffee served at 180-190°F, a temperature the company's own quality assurance manager admitted made the product "not fit for consumption."
This case analysis examines the factual record, trial proceedings, damages allocation, and product liability principles that continue to influence warning defect litigation three decades later. The verdict's subsequent reduction and confidential settlement prevented binding appellate precedent while amplifying its influence on tort reform debates nationwide.
McDonald's Coffee Lawsuit Factual Background
On February 27, 1992, Stella Liebeck, age 79, suffered third-degree burns covering 16% of her body after spilling McDonald's coffee in Albuquerque, New Mexico. Liebeck was a passenger in a parked vehicle when the coffee placed between her knees tipped while adding cream and sugar. Her cotton sweatpants absorbed liquid at 180-190°F, causing burns to her inner thighs, genitals, perineum, buttocks, and groin, requiring eight days of hospitalization, multiple skin graft procedures, and over two years of recovery with permanent disfigurement.
Liebeck initially sought $20,000 for medical expenses. McDonald's offered $800. Subsequent negotiations failed:
- Formal pre-litigation demand of $90,000: refused
- Settlement offer during litigation of $300,000: refused
- Independent mediator's recommendation of $225,000: refused
Legal Proceedings in the McDonald's Coffee Lawsuit
The complaint was filed in March 1993 in the Second Judicial District Court, Bernalillo County, New Mexico, advancing strict product liability under Restatement (Second) § 402A, negligence, and breach of implied warranty of merchantability. Judge Robert H. Scott denied McDonald's summary judgment motion, finding genuine issues of material fact.
McDonald's rejected multiple pre-trial settlement attempts. The company proceeded instead to a nine-day jury trial in August 1994.
Temperature Evidence in the McDonald's Coffee Case
Trial Exhibit 38 revealed McDonald's internal policy requiring coffee service at 180-190°F, approximately 20-30°F hotter than competitors. Dr. Charles J. Baxter of Southwestern Medical School testified that at 190°F, third-degree burns occur in 2-3 seconds versus approximately 20 seconds at 160°F, representing a critical safety margin.
Plaintiff's Exhibit No. 3 documented over 700 burn complaints received by McDonald's between 1982 and 1992, with settlements paid in prior cases. This evidence established:
- Actual knowledge of the burn hazard.
- Foreseeability of severe injuries.
- Foundation for punitive damages based on conscious disregard of known dangers.
McDonald's quality assurance manager Christopher Appleton testified that the company actively enforced a requirement that coffee be held at 185 degrees, plus or minus five degrees. Appleton acknowledged that coffee at serving temperature was "not fit for consumption" because it would burn the mouth and throat, an admission that proved particularly damaging, as it demonstrated internal corporate awareness that the product posed inherent dangers to consumers at the point of sale.
Appleton further acknowledged that McDonald's had received the 700 burn complaints over the preceding decade, exposed to prior litigation, yet maintained the same temperature policy. When asked whether the company had consulted burn experts before setting serving temperatures, Appleton admitted it had not.
McDonald's Coffee Lawsuit Verdict and Damages
Following a nine-day trial, the jury deliberated approximately four hours before allocating 80% liability to McDonald's and 20% comparative negligence to Liebeck. The jury awarded $200,000 compensatory damages (reduced to $160,000 after comparative fault) and $2.7 million punitive damages, approximately two days of McDonald's nationwide coffee sales revenue. The jury found McDonald's conduct "willful, wanton, and reckless."
Judge Scott exercised remittitur authority, reducing punitive damages to $480,000 (3:1 ratio), while characterizing McDonald's conduct as "reckless, callous, and willful." The parties reached a confidential settlement before appellate proceedings.
Product Liability Principles from the McDonald's Case
The case illustrated Restatement (Second) of Torts § 402A strict liability for products in "defective condition unreasonably dangerous." The warning defect theory proved more successful than design defect claims—the generic "Contents Hot" warning failed to communicate that coffee could cause third-degree burns requiring hospitalization within 2-3 seconds.
Courts continue to examine whether warnings adequately convey the nature, severity, and likelihood of harm rather than merely acknowledging a hazard's existence. A warning that states a product is "hot" differs fundamentally from one that specifies the product can cause permanent tissue damage requiring surgical intervention within seconds of contact.
Key distinctions in warning adequacy analysis:
- General hazard acknowledgment ("Contents Hot") versus specific severity disclosure (burn risk within seconds)
- Consumer expectation of harm versus actual injury potential at serving temperature
- Adequacy of warning placement, size, and conspicuousness relative to risk magnitude
Comparative negligence applied in this strict liability context, reducing compensatory damages proportionally to plaintiff's fault percentage while punitive damages served their distinct punishment and deterrence function. The jury's punitive damages determination required proof that McDonald's conduct exceeded ordinary negligence, meeting the heightened standard of willful, wanton, or reckless behavior through evidence of documented prior knowledge and continued dangerous practices.
The 80/20 liability allocation reflected the jury's assessment that while Liebeck bore some responsibility for the spill itself, McDonald's bore predominant responsibility for the severity of resulting injuries, a distinction critical to understanding how comparative fault operates in strict liability contexts.
Public Perception and Tort Reform Following the McDonald's Coffee Lawsuit
According to peer-reviewed scholarship, over 60% of survey respondents, 20 years post-verdict, continued to believe demonstrably false narratives about the case. Media coverage systematically omitted injury photographs, prior complaint history, and judicial reduction of damages. The case was invoked in tort reform debates across multiple state jurisdictions, contributing to punitive damage caps and procedural barriers despite representing legitimate product liability principles.
The confidential settlement prevented appellate review that might have established binding precedent on punitive damages calculation methodology. This settlement dynamic—common in high-profile cases where defendants seek to avoid precedential rulings—limited the case's formal legal authority while amplifying its influence on public discourse.
Multiple state legislatures cited the case when advancing tort reform measures throughout the 1990s, including caps on punitive damages in Texas and procedural barriers to punitive claims in other jurisdictions—reforms that remain in effect three decades later.
Practice Considerations from the McDonald's Coffee Lawsuit
The Liebeck verdict established litigation frameworks that continue to guide both plaintiff and defense counsel in product liability matters involving consumer injuries. Three decades of subsequent case law have refined these principles, though the core strategic lessons remain relevant for practitioners handling warning defect and temperature-related injury claims.
Plaintiff Strategy:
- Comprehensive discovery of prior incident reports establishes actual corporate knowledge.
- Comparative product testing with documented methodology creates demonstrative evidence.
- Pre-litigation demands supported by thorough documentation improve settlement positioning.
Defense Implications:
- Documented prior complaints without remedial action undermine defense positions.
- Deviation from industry standards without documented risk-benefit analysis creates liability exposure.
- Inadequate settlement offers become evidence of corporate indifference.
Future Outlook for Product Liability Cases
Constitutional standards governing punitive damages have evolved substantially since the 1994 verdict. The Supreme Court's decisions in BMW v. Gore (1996), State Farm v. Campbell (2003), and Philip Morris v. Williams (2007) established explicit due process constraints that Judge Scott's remittitur anticipated. Contemporary courts apply presumptive single-digit multiplier guidelines, though awards exceeding these ratios remain permissible in cases involving particularly egregious conduct.
Corporate compliance programs have matured significantly in response to product liability exposure. Modern risk management frameworks emphasize real-time complaint tracking with automated severity escalation, cross-departmental safety committees with documented decision-making authority, and privileged internal investigations conducted under attorney-client protection.
For practitioners handling similar cases today, prior complaint discovery remains the most critical element of case development. Contemporary courts apply more restrictive proximate cause analysis, increasingly scrutinizing whether plaintiff conduct constitutes a superseding cause that limits manufacturer liability.
Why the McDonald's Coffee Lawsuit Still Matters
Liebeck v. McDonald's remains a foundational authority on product liability, duty to warn, and punitive damages calibration. The confidential settlement prevented formal appellate precedent while substantially influencing practitioner strategy, corporate risk management, and legislative reform across multiple jurisdictions.
Effective litigation of similar claims requires thorough documentation of prior incidents, comprehensive evidence of corporate knowledge, and systematic organization of temperature evidence and medical records that establish the severity and foreseeability of injuries.
For additional context on how courts evaluate punitive damages across jurisdictions, see the punitive damage caps guide.
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