Escola v. Coca Cola Bottling Co.

Supreme Court of California
24 Cal. 2d 453 (1944)

ELI5:

Rule of Law:

The doctrine of res ipsa loquitur may be applied against a defendant manufacturer for a defective product even if the defendant has relinquished control of the instrumentality, provided the plaintiff proves the product's condition did not change after leaving the defendant's possession and the plaintiff handled it carefully.

Facts:

Defendant, Coca-Cola Bottling Co., bottled and delivered several cases of its beverage to the restaurant where plaintiff, Escola, worked as a waitress.
Defendant's driver placed the cases on the floor under a counter, where they remained for at least 36 hours.
Escola moved the top case from the floor to a nearby ice cream cabinet.
Escola then began transferring individual bottles from the case to a refrigerator.
While moving the fourth bottle, it spontaneously exploded in her hand before she could place it in the refrigerator.
The explosion inflicted a deep five-inch cut on Escola's hand, severing blood vessels, nerves, and muscles.
Witnesses testified that Escola did not strike the bottle against any object before it exploded and that it made a loud popping sound.

Procedural Posture:

Plaintiff Escola sued defendant Coca-Cola Bottling Co. in a state trial court for negligence.
The case was tried before a jury.
The jury returned a verdict in favor of the plaintiff, Escola.
The trial court entered a judgment on the verdict for the plaintiff.
Defendant, Coca-Cola Bottling Co., as the appellant, appealed the judgment to the Supreme Court of California.

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Issue:

Does the doctrine of res ipsa loquitur apply against a bottling company when a bottle of its carbonated beverage explodes in the hands of a person after it has left the company's possession and control?

Opinions:

Majority - Gibson, C. J.

Yes. The doctrine of res ipsa loquitur applies because the evidence was sufficient for a jury to infer the defendant's negligence. The traditional requirement of exclusive control is met if the defendant had control at the time of the alleged negligent act (bottling), and the plaintiff can demonstrate that the instrumentality's condition did not change after leaving the defendant's control. Here, Escola presented evidence that the bottle was handled carefully after delivery, permitting a reasonable inference that it was defective when it left the Coca-Cola Bottling Co.'s possession. Sound bottles of carbonated beverages do not ordinarily explode, so the accident implies negligence. Whether the cause was an excessive pressure charge or a defect in the glass, both possibilities point to negligence within the defendant's exclusive control over the charging and inspection process.

Concurring - Traynor, J.

Yes, but the court should base its holding on a rule of absolute liability rather than negligence. Public policy demands that a manufacturer who places a product on the market incurs absolute liability when that product has a defect that causes injury to human beings, regardless of whether the manufacturer was negligent. The manufacturer is best situated to anticipate risks, insure against them, and distribute the cost to the public. Relying on res ipsa loquitur is a circuitous way of imposing liability without fault; the court should instead openly declare that manufacturers are strictly liable for injuries caused by their defective products.

Analysis:

This case significantly expanded the application of res ipsa loquitur in products liability by relaxing the 'exclusive control' requirement, making it easier for plaintiffs to bring negligence claims against manufacturers even after a product has entered the stream of commerce. More importantly, Justice Traynor's influential concurring opinion laid the intellectual foundation for the doctrine of strict products liability. His argument that public policy should impose liability on manufacturers for defective products, irrespective of negligence, became the blueprint for modern products liability law, which California would later adopt.

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