## Facts

- Seventy-nine-year-old Stella Liebeck went to a McDonald’s drive-through in Albuquerque, New Mexico, with her grandson and bought a cup of coffee.
- After the purchase, the car stopped so Liebeck could add cream and sugar.
- While handling the cup, Liebeck spilled the coffee into her lap.
- The spill caused third-degree burns over about 16% of her body, including sensitive areas, and required skin grafts.
- Liebeck spent eight days in the hospital and underwent about two years of follow-up medical treatment.
- Liebeck asked McDonald’s to pay about $20,000 to cover her losses; McDonald’s offered $800.
- Liebeck sued McDonald’s under products-liability and negligence theories, alleging the coffee was defectively hot and that the warnings did not adequately convey the burn risk.
- McDonald’s had a written policy to serve coffee at approximately 180°F to 190°F, about 20°F hotter than competitors’ coffee.
- Both sides presented testimony about whether that serving temperature was reasonable for customers, including evidence that at 190°F third-degree burns can occur in under three seconds, at 180°F in about 12–15 seconds, and at 160°F in about 20 seconds.
- Evidence showed McDonald’s had received more than 700 reports of burn injuries from its coffee in the prior 10 years and had paid more than $500,000 to resolve related claims.
- McDonald’s argued the number of incidents was small compared to the volume of coffee sold and contended Liebeck was responsible for the spill; Liebeck argued the coffee was not fit for consumption as served and posed a severe scald risk if spilled.

## Issues

1. Whether McDonald’s coffee, served at approximately 180°F to 190°F, was unreasonably dangerous (defective) under products-liability principles.
2. Whether McDonald’s failed to give an adequate warning about the speed and severity of burns that could result from a spill at that temperature.
3. Whether McDonald’s knowledge of prior burn incidents and continuation of its temperature policy supported an award of punitive damages.
4. How comparative fault should be allocated between Liebeck and McDonald’s, and how that allocation affected compensatory damages.
5. Whether the punitive damages award should be reduced after trial.

## Decision

- The jury found McDonald’s liable and assigned 80% fault to McDonald’s and 20% fault to Liebeck.
- The jury awarded $200,000 in compensatory damages, reduced to $160,000 to account for Liebeck’s comparative fault.
- The jury awarded punitive damages of approximately $2.7 million (often described as close to $3 million).
- After trial, the judge reduced punitive damages to $480,000 (three times the compensatory award), resulting in a total award of $640,000.
- The judge denied McDonald’s request for a new trial.
- McDonald’s pursued an appeal, but the case later resolved through a confidential settlement and did not produce a published appellate opinion.

## Legal Principles

- A seller may be liable for a product that creates an unreasonable risk of serious injury in a foreseeable use or foreseeable mishandling, including spills.
- Failure-to-warn liability may arise when a seller knows or should know of a risk of serious harm and the warning does not reasonably convey the nature and severity of that danger.
- Evidence of prior similar incidents and continued adherence to a challenged policy may support a finding that the defendant acted with reckless disregard for consumer safety, permitting punitive damages.
- Comparative negligence permits fault allocation between plaintiff and defendant and reduces compensatory damages in proportion to the plaintiff’s share of fault.
- A trial judge may reduce a punitive damages award through remittitur when the judge concludes the amount exceeds what is justified by punishment and deterrence relative to the compensatory award.

## Conclusion

In *Liebeck v. McDonald’s Restaurants*, a New Mexico state-court jury found McDonald’s liable after Stella Liebeck suffered severe third-degree burns from spilled drive-through coffee served pursuant to a 180°F to 190°F policy, awarded $200,000 in compensatory damages (reduced to $160,000 for 20% comparative fault) and roughly $2.7 million in punitive damages, and the trial judge later reduced the punitive award to $480,000 for a total of $640,000; the case later settled without a published appellate decision.


Liebeck v. McDonald's Restaurants, 1995 WL 360309 (1994)