--- title: "Liebeck v. McDonald's Restaurants" type: Landmark Case source: https://casebriefly.com/landmark-cases/liebeck-v-mcdonalds --- # Liebeck v. McDonald's Restaurants Liebeck v. McDonald's is the most publicly discussed tort case in American history and is central to the debate over tort reform. While often cited by critics as an example of frivolous litigation, the case actually involved severe third-degree burns caused by coffee served at dangerously high temperatures, and the jury found that McDonald's was aware of the risk and chose not to reduce the temperature. The case illustrates the proper functioning of products liability and punitive damages. ## Citation No. D-202 CV-93-02419 (N.M. Dist. Ct. 1994) ## Year 1994 ## Court New Mexico District Court, Second Judicial District ## Facts Stella Liebeck, a 79-year-old woman, purchased a cup of coffee from a McDonald's drive-through in Albuquerque, New Mexico. While parked, she placed the cup between her knees to remove the lid and add cream and sugar. The coffee spilled onto her lap, causing third-degree burns over 16 percent of her body, including her inner thighs, groin, and buttocks. She required extensive hospitalization, skin grafts, and two years of medical treatment. Evidence showed McDonald's served its coffee at 180-190 degrees Fahrenheit, far hotter than coffee served at home or by competitors, and that over 700 prior burn claims had been filed against the company. ## Procedural History Liebeck initially offered to settle for $20,000 to cover her medical expenses, but McDonald's refused. The case went to trial, and the jury awarded $200,000 in compensatory damages (reduced to $160,000 for 20% comparative fault) and $2.7 million in punitive damages (roughly two days of McDonald's coffee revenue). The trial judge reduced the punitive damages to $480,000. The parties ultimately settled for a confidential amount. ## Issue Whether McDonald's was liable for injuries caused by coffee served at an unreasonably dangerous temperature, and whether the company's knowledge of the risk and failure to act warranted punitive damages. ## Holding The jury found that McDonald's coffee was defectively dangerous, that McDonald's knew of the risk and failed to adequately warn or reduce the temperature, and that the company's conduct warranted punitive damages. The jury assigned 80% fault to McDonald's and 20% to Liebeck. ## Reasoning The jury considered evidence that McDonald's served its coffee at 180-190 degrees Fahrenheit, which is capable of causing third-degree burns within seconds of contact with skin. Expert testimony established that coffee served at lower temperatures would cause less severe injuries and allow time for the victim to remove clothing and limit contact. McDonald's was aware of over 700 prior burn complaints but had made a corporate decision not to lower the temperature, partly because its consultants told it that reducing temperature might affect taste. The jury found this decision-making reflected a conscious disregard of a known danger, warranting punitive damages. ## Impact Liebeck became a flashpoint in the American tort reform debate. Opponents of the tort system held it up as an example of runaway juries, while proponents argued it was a case where the system worked as intended — holding a corporation accountable for knowingly serving a dangerous product. The case influenced public perception of tort law, prompted legislative efforts to cap punitive damages, and is regularly used in law school to teach about products liability, comparative fault, and the role of punitive damages. ## Key Quotes - McDonald's quality assurance manager testified that McDonald's coffee was 'not fit for consumption' at the temperature served because it would burn the mouth and throat. - McDonald's had received more than 700 previous reports of burns from its coffee, some involving third-degree burns similar to Liebeck's. ## Related Cases - bmw-of-north-america-v-gore - greenman-v-yuba-power-products - escola-v-coca-cola-bottling - macpherson-v-buick-motor-co ## Exam Relevance Liebeck is used to test understanding of products liability (design defect and failure to warn), comparative fault, and punitive damages. Students should be prepared to analyze whether the coffee was unreasonably dangerous, discuss the role of prior knowledge, and evaluate the appropriateness of punitive damages. ## Study Tips - Know the actual facts — the popular narrative omits critical details like the severity of the burns and McDonald's prior knowledge of the risk. - Use this case to illustrate the design defect theory: the product (coffee at 180-190 degrees) was more dangerous than a reasonable consumer would expect. - Connect the punitive damages analysis to BMW v. Gore's three guideposts, which were articulated two years later. - Be prepared to discuss the tort reform debate and how this case has been used to argue both for and against limiting tort remedies. ## Doctrine Established Products Liability for Unreasonably Dangerous Consumer Products --- Source: [Liebeck v. McDonald's Restaurants — CaseBriefly](https://casebriefly.com/landmark-cases/liebeck-v-mcdonalds)