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Escola v. Coca Cola Bottling Co.

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Brief Fact Summary.

Escola (Plaintiff) was injured when a bottle filled by Coca Cola Bottling Co. (Defendant) broke in her hand.

Synopsis of Rule of Law.

Manufacturers are responsible for all defects in their products regardless of which part of the process results in them.

Points of Law - Legal Principles in this Case for Law Students.

The retailer, even though not equipped to test a product, is under an absolute liability to his customer, for the implied warranties of fitness for proposed use and merchantable quality include a warranty of safety of the product.

View Full Point of Law
Facts.

Coca Cola Bottling Co. (Defendant) bottled beverages. The bottle in question was either overfilled or the bottle itself was defective. This bottle was delivered to the employer of Escola (Plaintiff). It broke in Plaintiff’s hand while she was waitressing.

Issue.

Is Defendant liable for the injuries to Plaintiff regardless of what the actual defect was?

Held.

Yes, the Court held that Defendant is liable.

Concurrence.

Justice J. Traynor

The concurrence believes absolute liability should be the standard for injuries to plaintiffs from defective manufactured products. It is more efficient for the manufacturer to guard against these potential injuries than plaintiffs, so the burden should be on them. Plaintiffs are not as familiar with the manufacturing process as defendants and would have a harder time proving their cases with a negligence standard. Finally, the concurrence argues that actions of both makers of foods and retailers are viewed under absolute liability, so this should be extended to all manufacturers.

Discussion.

The Court discusses how it is unknown whether the defect came from the bottle itself or from Defendant overfilling the bottle. However, it says it does not matter which, because both would be the result of negligence. A defect in the bottle would be discovered by testing and Defendant should have been careful not to overfill the bottle. Therefore, under a res ipsa loquitur theory, the Court found Defendant liable.


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