Bruner v. Anheuser-Busch, Inc.
153 F.Supp.2d 1358, 2001 WL 880253, 2001 U.S. Dist. LEXIS 15382 (2001)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A manufacturer of alcoholic beverages is not liable under a theory of strict products liability for injuries resulting from the over-consumption of its products because the dangers of alcohol are common knowledge, rendering the product not 'unreasonably dangerous.' Furthermore, the proximate cause of such injuries is the voluntary act of consumption, not the manufacture or sale of the beverage.
Facts:
- During the late 1960s and early 1970s, David W. Bruner and David W. Pitchford consumed large quantities of Budweiser beer, which is produced by Anheuser-Busch.
- Bruner and Pitchford alleged that they were lured to consume the beer through advertising and marketing.
- The plaintiffs believed the consumption of Budweiser was safe based on what they perceived as fraudulent representations made by Anheuser-Busch.
- As a result of their long-term alcohol consumption, Bruner and Pitchford suffered negative consequences, including incarcerations and the loss of their families, jobs, and income.
Procedural Posture:
- David W. Bruner and David W. Pitchford filed a complaint against Anheuser-Busch in the U.S. District Court.
- Anheuser-Busch filed a Motion to Dismiss for failure to state a claim upon which relief can be granted, pursuant to Federal Rule of Civil Procedure 12(b)(6).
- The plaintiffs filed a response opposing the motion.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a beer manufacturer have a legal duty to warn consumers of the dangers of alcohol consumption, and can it be held strictly liable for injuries resulting from such consumption, when those dangers are considered common knowledge?
Opinions:
Majority - Middlebrooks
No. A beer manufacturer does not have a legal duty to warn of commonly known dangers and cannot be held strictly liable for injuries resulting from alcohol consumption. Under the Restatement (Second) of Torts § 402A, adopted in Florida, a manufacturer is only strictly liable if its product is 'unreasonably dangerous.' A product is deemed unreasonably dangerous only if it is dangerous to an extent beyond that contemplated by the ordinary consumer with common community knowledge. The court determined that the potential dangers associated with alcohol abuse are common knowledge. Therefore, beer is not an unreasonably dangerous product. Additionally, the court found that under Florida common law, the proximate cause of injuries from intoxication is the voluntary act of drinking the alcohol, not the act of manufacturing or selling it.
Analysis:
This decision solidifies the 'common knowledge' doctrine as a robust defense for manufacturers of products with inherent, widely-known risks, such as alcohol. It establishes that in products liability cases involving such products, the legal focus shifts from the manufacturer's duty to warn to the consumer's assumption of risk. This precedent makes it exceedingly difficult for plaintiffs to bring successful claims against alcoholic beverage companies for damages arising from the intended use and known risks of their products, effectively insulating the industry from liability for the consequences of alcohol abuse.
