Liebeck v. McDonald's Restaurants

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Liebeck v. McDonald's Restaurants is a landmark 1994 product liability lawsuit heard in New Mexico, US, that became one of the most widely referenced and frequently misrepresented tort cases in modern American legal history. It was filed after 79-year-old Stella Liebeck suffered severe permanent scald injuries from coffee served at an unsafe, excessively high temperature by a local McDonald's franchise location.

Key moments

1992-02-27Stella Liebeck spills a 49-cent drive-thru McDonald's coffee onto her lap while parked in her car to add cream and sugar, sustaining third-degree burns on 6% of her skin and minor burns across 16% of her body, requiring 8 days of hospitalization, skin graft procedures, and two full years of follow-up medical treatment.
Pre-trial settlement negotiations take place: Liebeck first requests $20,000 to cover her medical expenses, but McDonald's offers only $800, prompting Liebeck to formally file a negligence lawsuit against the chain for selling unreasonably dangerous hot coffee.
1994-08-18A Bernalillo County jury rules in Liebeck's favor, awarding her compensatory damages plus $2.7 million in punitive damages. The judge later reduces the total award to roughly $640,000, and the two parties ultimately reach a private out-of-court settlement for an undisclosed sum.
The ruling sparks multi-decade national debate in the US over tort reform, corporate customer safety obligations, and the line between legitimate injury claims and alleged frivolous litigation.

Widespread Public Misrepresentation of the Case

Most popular mainstream popular retellings of the lawsuit intentionally omit critical context that justified the jury's decision: McDonald's had received over 700 separate documented customer burn complaints related to its overheated coffee in the 10 years prior to the incident, and had taken no meaningful action to adjust its serving standards. The 180–190 °F coffee McDonald's required all franchises to serve could cause permanent third-degree burns in 2 to 7 seconds, far hotter than the 130–160 °F standard coffee temperature used by most other dining establishments at the time. This selective omission created a widespread false public narrative that the case was an example of an absurd, undeserved legal windfall for an irresponsible plaintiff.

Sweeping Long-Term Industry and Policy Impacts

Beyond the private settlement between the two parties, the case drove near-universal operational changes across the entire global fast food sector: nearly all major quick service chains lowered the standard serving temperature of hot coffee and other hot beverages to the 155–175 °F range, added prominent, high-contrast warning labels noting extreme heat on all disposable hot drink cups, and updated internal food safety policies to reduce customer burn risk. The case has also remained a core, frequently cited reference point for both sides of US national tort reform legislative debates for more than 30 years after the original verdict was issued.

Overview

Liebeck v. McDonald's Restaurants

full name	Stella Liebeck v. McDonald's Restaurants, P.T.S., Inc. and McDonald's International, Inc.
date decided	August 18, 1994
citations	1994 Extra LEXIS 23 (Bernalillo County, N.M. Dist. Ct. 1994), 1995 WL 360309 (Bernalillo County, N.M. Dist. Ct. 1994),
judges	Robert H. Scott
court	Second Judicial District Court, Bernalillo County

Liebeck v. McDonald's Restaurants, also known as the McDonald's coffee case and the hot coffee lawsuit, was a highly publicized 1994 product liability lawsuit in the United States against the restaurant corporation McDonald's

Trial

The trial took place from August 8 to 17, 1994, before New Mexico District Court Judge Robert H. Scott.[18] During the case, Liebeck's attorneys discovered that McDonald's required franchisees to hold coffee at 180 - 190 F. Liebeck's attorneys argued that coffee should never be served hotter than 140 F, and that a number of other establishments served coffee at a substantially lower temperature than McDonald's. The attorneys presented evidence that coffee they had tested all over the city was served at a temperature at least 20 °F (11 °C) lower than McDonald's coffee. They also presented the jury with expert testimony that 190 F coffee may produce third-degree burns (where skin grafting is necessary) in about three seconds and 180 F coffee may produce such burns in about 12 to 15 seconds.[10] Lowering the temperature to 160 F would increase the time for the coffee to produce such a burn to 20 seconds. Liebeck's attorneys argued that these extra seconds could provide adequate time to remove the coffee from exposed skin, thereby preventing many burns.[19]

McDonald's claimed that the reason for serving such hot coffee in its drive-through windows was that those who purchased the coffee typically were commuters who wanted to drive a distance with the coffee; the high initial temperature would keep the coffee hot during the trip. However, it was found that McDonald's had carried out research finding that customers intend to consume the coffee immediately while driving.[20] McDonald's had also received advice from consultants that high temperatures are necessary in brewing to fully extract the flavor.[10]

Other documents showed that, from 1982 to 1992, McDonald's had received more than 700 reports of people burned by its coffee to varying degrees of severity, and had settled claims arising from scalding injuries for more than $500,000.[10] McDonald's quality control manager, Christopher Appleton, testified that this number was insufficient to cause the company to evaluate its practices. He argued that all foods hotter than 130 °F constituted a burn hazard, and that restaurants had more pressing dangers to worry about. The plaintiffs argued that Appleton conceded that McDonald's coffee would burn the mouth and throat if consumed when served.[10]

Verdict

A twelve-person jury reached its verdict on August 18, 1994.[18] Applying the principles of comparative negligence, the jury found that McDonald's was 80% responsible for the incident and Liebeck was 20% at fault. Though there was a warning on the coffee cup, the jury decided it was neither large enough nor sufficient. They awarded Liebeck $200,000 in compensatory damages, which was reduced by 20% to $160,000. In addition, they awarded her $2.7 million in punitive damages. According to The New York Times, the jurors arrived at this figure from Morgan's suggestion to penalize McDonald's for two days of coffee revenues, about $1.35 million per day.[8][10]

The judge reduced punitive damages to $480,000,[21] three times the compensatory amount, for a total of $640,000.[16]

Liebeck v. McDonald's Restaurants

WorldBrand briefing

Widespread Public Misrepresentation of the Case

Sweeping Long-Term Industry and Policy Impacts

Burn incident

Attempts to settle

Trial

Verdict

Aftermath

Similar lawsuits

See also

Bibliography

Further reading

External links

References

Coffee temperature

Hot Coffee documentary

The New York Times Retro Report