McMahon v. Bunn-O-Matic Corp.

Brief Fact Summary.

Plaintiff suffered second and third degree burns after spilling hot coffee on herself. Plaintiff sued Defendant. The district court awarded summary judgment to Defendant. Plaintiff appealed.

Synopsis of Rule of Law.

If the public is aware that a product is dangerous in general, there is no need for an overly detailed warning about the product’s danger.

Facts.

McMahon (Plaintiff) bought a cup of coffee from a gas station. When attempting to pour the coffee into a smaller cup, the coffee spilled on her lap and caused second and third degree burns. Plaintiff sued Bunn-O-Matic Corp. (Defendant) alleging that Defendant failed to warn consumers about the severity of hot coffee burns and that Defendant’s machines produced coffee that was too hot for human consumption. Plaintiff claimed that although she knew hot coffee would burn, she was unaware of the severity of the potential burns.

Issue.

Whether an overly detailed warning about a product’s danger required if the public knows that it is dangerous in general.

Held.

No. The district court’s ruling was affirmed. If the public knows about a product’s danger in general, then an overly detailed warning about the product’s danger is not required.

Discussion.

The law “expects consumers to educate themselves about the hazards of daily life.†It is common knowledge that coffee can burn and any further detail about the potential severity of the burns would be counterproductive. Additionally, overly detailed warnings are less likely to be remembered in full and the resulting smaller text makes it more difficult for consumers to read. Furthermore, hot coffee, even at the temperature that Defendant’s machines serve it, gives consumers many benefits such as maintenance of drinking temperature, smell, and taste. Moreover, a product is not defective simply because its purpose is potentially dangerous.