Escola v. Coca Cola Bottling Co. of Fresno

Brief Fact Summary. A bottle of Coke manufactured by Coca Cola Bottling Co. of Fresno (Defendant) exploded in Escola’s (Plaintiff’s) hand. Absolute liability was imposed on Defendant.

Synopsis of Rule of Law. A manufacturer incurs absolute liability when an article that he has placed on the market, knowing that it is to be used without inspection, proves to have a defect that causes injury to humans.

Facts. Plaintiff was a waitress, and one of her duties was to stock the refrigerator with bottles of Coca-Cola. On one occasion, a bottle exploded in Plaintiff’s hand as she was putting it into the refrigerator, causing serious injury. Plaintiff sued Defendant, claiming that Defendant was negligent in selling “bottles containing said beverage which on account of excessive pressure of gas or by reason of some defect in the bottle was dangerous.and likely to explode.” The jury returned a verdict for Plaintiff. Defendant appealed.

Issue. Is Defendant absolutely liable for its failure to inspect a bottle of Coca-Cola that proves to have a defect that causes injury to Plaintiff?

Held. Yes. Judgment affirmed.
* Using the doctrine of res ipsa loquitur, the majority inferred negligence upon Defendant.
Concurrence. (Justice Traynor) A manufacturer incurs absolute liability when an article that he has placed on the market, knowing that it is to be used without inspection, proves to have a defect that causes injury to humans.
* Irrespective of privity of contract, the manufacturer is responsible for an injury caused by an article, to any person who comes in lawful contact with it. Even if there is no negligence, public policy demands that responsibility be placed where it will most effectively reduce the hazards of life and health inherent in defective products that reach the market.
* Those who suffer injury from defective products are unprepared to meet its consequences. The cost of an injury and the loss of time or health may be an overwhelming misfortune to the person injured, and a needless one, for the risk of injury can be insured by the manufacturer and distributed among the public as the cost of doing business.
* If public policy demands that a manufacturer of goods be responsible for its quality regardless of negligence, there is no reason not to fix that responsibility openly.
* The liability of the manufacturer to an immediate buyer injured by a defective product follows without proof of negligence from the implied warranty of safety attending the sale.
* Consumers will no longer need to be wary of products. The manufacturer’s obligation to the consumer must keep pace with the changing relationship between them.

Discussion. The majority held that the inference of negligence under the doctrine of res ipsa loquitur shifted the burden of proof to the Defendant. In J. Traynor’s concurring opinion, Defendant is strictly liable to Plaintiff. Plaintiff need not utilize the doctrine of res ipsa loquitur.