Liebeck v. McDonald’s Hot Coffee Case: Burns, Verdict, and Myths

The Liebeck v. McDonald’s hot coffee case, tried in Albuquerque in August 1994, involved a 79-year-old woman who suffered third-degree burns from coffee served at nearly 190°F, spent eight days in the hospital, needed skin grafts, and asked McDonald’s for roughly $20,000 to cover her medical bills before the company offered her $800. A jury awarded $2.86 million. The trial judge cut that figure sharply, and the parties then settled for a confidential amount widely believed to be smaller still. The case is remembered as a punchline about frivolous lawsuits. The trial record tells a different story.¹

The Injury Was Not a Minor Burn

Stella Liebeck was riding in the passenger seat of her grandson’s Ford Probe on a February morning in 1992. They had bought a 49-cent coffee from a McDonald’s drive-through, and her grandson pulled into a parking space so she could add cream and sugar. She placed the styrofoam cup between her knees and pulled off the lid. The cup tipped and emptied into her lap.¹

Her cotton sweatpants soaked through and held the liquid against her skin. She suffered third-degree burns across six percent of her body and lesser burns on another ten percent. The deepest burns reached her inner thighs, groin, and buttocks, destroying skin down through the layers of muscle and fatty tissue. She was hospitalized for eight days, underwent skin grafts, endured months of follow-up procedures, and lost roughly 20 percent of her body weight during recovery.¹

McDonald’s Served Coffee Hot Enough to Burn in Seconds

Trial evidence showed that McDonald’s operations and training manual required franchisees to hold coffee at 180 to 190 degrees Fahrenheit. At that temperature, spilled coffee causes third-degree burns in under three seconds. An expert witness for Liebeck testified that dropping the serving temperature to around 160°F would stretch that window to roughly 20 seconds, long enough to pull soaked clothing away from the skin.¹

A reporter who checked coffee temperatures at other restaurants in the same city found none within 20 degrees of McDonald’s. The Shriner’s Burn Institute in Cincinnati had already warned the franchise food industry that serving beverages above 130°F was causing unnecessary scald injuries. McDonald’s own scientist conceded at trial that any coffee above 130°F could cause third-degree burns, but told the jury that the precise temperature therefore did not matter.

The most damaging evidence came from McDonald’s own files. Over the prior ten years, the company had received more than 700 complaints from customers, including children, who had been burned by its coffee. Internal documents showed the company had paid out over $500,000 to settle earlier burn claims. Despite that record, McDonald’s had not lowered its coffee temperature, changed its cups, or added stronger warnings. A corporate representative testified that the number of burn injuries was statistically insignificant given the billions of cups sold.¹

She Tried to Settle for Her Medical Bills

Before filing suit, Liebeck wrote to McDonald’s asking the company to cover her medical bills and lost income, a figure of roughly $15,000 to $20,000. Her out-of-pocket medical expenses alone came to about $11,000. McDonald’s replied with a letter offering $800.¹

She spent six months trying to negotiate before hiring an attorney. Even after the lawsuit was filed, she reportedly remained willing to settle for a modest sum. The refusal to move off $800 is what put a 79-year-old woman with no prior litigation history in front of a jury.

How the Jury Arrived at $2.86 Million

The nine-day trial took place in August 1994 before Judge Robert H. Scott in the Second Judicial District Court of Bernalillo County, New Mexico. The jury found McDonald’s liable for selling a defectively dangerous product.

Jurors awarded $200,000 in compensatory damages for medical costs, lost income, pain, and disability. They also applied comparative negligence, finding Liebeck 20 percent responsible for the spill because she placed the cup between her knees and removed the lid. That finding cut the compensatory award to $160,000.²

The jury then set punitive damages at $2.7 million. That number was not pulled from the air. Jurors deliberately calculated it to equal roughly two days of McDonald’s national coffee revenue, on the reasoning that a company that had absorbed hundreds of burn injuries over a decade without changing its practices would only notice a punishment measured against its actual sales. Punitive damages exist to punish and deter, not to compensate, and the jury pegged the figure to what would function as deterrence.¹

Combined with the reduced compensatory damages, the initial verdict totaled approximately $2.86 million.²

What Liebeck Actually Received

Days after the verdict, Judge Scott announced he would reduce the punitive damages through remittitur, a procedure that allows a trial judge to lower an award deemed excessive. He cut the $2.7 million punitive figure to $480,000, three times the net compensatory damages. That brought the total post-remittitur award to $640,000.²

Both sides appealed. Before any appellate court ruled, Liebeck and McDonald’s reached a confidential settlement. The amount was never disclosed, though it is widely understood to have been less than $640,000. Because the case settled, no published appellate opinion emerged to set precedent on serving-temperature liability.²

The “millions” figure that stuck to the case in public memory was never paid.

How the Case Became a Punchline

Within days of the verdict, the case was reduced to a one-line joke: woman spills coffee, sues, wins millions. That version left out Liebeck’s age, the severity of her burns, the three-second burn threshold, the 700 prior complaints, the $800 offer, the 20 percent fault finding, the judge’s reduction, and the confidential settlement. It left out, in other words, every fact that made the jury’s decision reasonable.

The distortion had help. Corporate advocacy groups used the case as the anchor exhibit in a national campaign for tort reform, arguing that the civil justice system was overrun with frivolous claims. In 2011, trial lawyer Susan Saladoff released the documentary “Hot Coffee,” which walked through the trial evidence and helped correct parts of the public record.¹

The tort reform push that followed the verdict succeeded at the state level across much of the country. Many states capped punitive damages, often at a fixed multiple of compensatory damages, and raised the evidentiary standard required to obtain them. At the federal level, Congress took up the Common Sense Product Liability Legal Reform Act of 1995, which proposed a “clear and convincing evidence” standard for punitive awards and other restrictions on product liability suits; that bill did not become law.³

What often gets lost is that every check built into the system did operate in Liebeck’s case. The jury weighed the evidence, assigned proportional fault, and set a punitive figure tied to the defendant’s revenue. The judge reviewed the award and cut it by more than 80 percent. The parties then settled quietly. The headline number was the only piece of that sequence most people ever heard.

1
American Museum of Tort Law. Liebeck v. McDonalds
2
Cornell Law Institute. Liebeck v. McDonald’s Restaurants (1994)
3
Congress.gov. H.R.917 – Common Sense Product Liability Reform Act