Lee v. Crookston Coca-Cola Bottling Co.

Supreme Court of Minnesota
188 N.W.2d 426 (1971)

ELI5:

Rule of Law:

Circumstantial evidence sufficient to support a jury instruction on negligence under the doctrine of res ipsa loquitur is also sufficient to submit a claim of strict liability in tort to the jury in a product liability case.

Facts:

Crookston Coca-Cola Bottling Company's driver delivered a case of Coca-Cola bottles to the Norman Steak House.
The case was stacked behind a counter and remained undisturbed for approximately 30 to 60 minutes.
Helen Lee, a waitress, began transferring the bottles from the case into a refrigerated cooler.
While Lee was lowering the third bottle into the cooler, it exploded in her right hand.
Lee testified unequivocally that she did not strike the bottle on anything before it exploded.
The explosion was loud enough for the manager to hear it from the kitchen, and glass fragments were scattered up to twelve feet away.
The bottle fragments were swept up and discarded shortly after the incident.

Procedural Posture:

Helen Lee and her husband sued Crookston Coca-Cola Bottling Company in a Minnesota trial court.
Plaintiffs' complaint asserted claims based on breach of implied warranty, negligence under res ipsa loquitur, and strict tort liability.
The trial court submitted the case to the jury only on the theories of breach of warranty and negligence, refusing plaintiffs' request for an instruction on strict liability.
The court also submitted the issue of plaintiff's contributory negligence to the jury over plaintiffs' objection.
The jury returned a general verdict for the defendant, Crookston Coca-Cola.
Plaintiffs filed a motion for a new trial, which the trial court denied.
Plaintiffs appealed the denial of the new trial motion to the Supreme Court of Minnesota.

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Issue:

Is circumstantial evidence, which is sufficient to support a negligence claim under the doctrine of res ipsa loquitur, also sufficient to submit a claim of strict liability in tort to the jury in a product liability case?

Opinions:

Majority - Rogosheske, Justice

Yes. Where circumstantial evidence allows an inference that it is more probable than not that a product was defective when it left the defendant's control, that evidence is sufficient to submit the issue of liability to the jury on both negligence and strict liability theories. The court reasoned that the policy goals of strict liability—promoting public safety and placing the burden of loss on the manufacturer—are served by allowing plaintiffs to prove a defect through circumstantial evidence, especially when the product itself is destroyed by the defect. Proving a specific defect is not required; it is sufficient that the evidence reasonably infers the product was defective when it left the manufacturer's control. The court also held it was reversible error to submit the issue of contributory negligence to the jury because the only evidence supporting it—an expert's opinion—was based on a hypothetical assumption that the plaintiff struck the bottle, a fact directly contradicted by all eyewitness testimony and therefore lacking proper foundation.

Dissenting - Peterson, Justice

No. The majority's holding effectively imposes absolute liability on manufacturers, making them insurers of their products. The decision allows the doctrine of res ipsa loquitur to compel a finding for the plaintiff rather than merely permitting an inference of negligence or defect. This approach strips manufacturers of any meaningful defense, as they cannot practically counter a plaintiff's self-serving testimony that they did not mishandle the product. The dissent argued that the trial court committed no prejudicial error and its decision should be affirmed.

Analysis:

This decision significantly lowers the evidentiary bar for plaintiffs in product liability cases, particularly those involving exploding containers or other situations where the product is destroyed by the alleged defect. By holding that the same circumstantial evidence used for a res ipsa loquitur negligence claim can also sustain a strict liability claim, the court allows plaintiffs to reach a jury without direct proof of a specific defect. This strengthens the position of consumers by focusing the jury's inquiry on the condition of the product itself, rather than the manufacturer's conduct, thereby advancing the core principles of strict liability doctrine.

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