Shih v. Starbucks Corp.
53 Cal.App.5th 1246 (Modified and Certified for Publication) (2020)
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Rule of Law:
Even if a product defect or negligent conduct is a cause-in-fact of an injury, it does not constitute a legal or proximate cause if the harm results from an attenuated chain of events that is outside the scope of risks generally increased by the tortious aspect of the defendant’s conduct.
Facts:
- Tina Shih and a friend went to a Starbucks store and each ordered a cup of hot tea.
- Shih retrieved the two drinks, which were double-cupped and extremely hot, but neither had a sleeve around the outer cup, and the tea was filled to the brim.
- Shih carried the two drinks, one in each hand, to a table in the store and set them down.
- Shih sat at the table, removed the lid from her drink, and attempted to bend forward to take a sip from the open cup.
- While attempting to sip, Shih tried to push her chair slightly, but the chair moved more than she anticipated.
- Shih grabbed onto the table to maintain her balance, which caused her drink to spill.
- The spilled hot tea caused Shih to suffer second-degree burns.
Procedural Posture:
- Tina Shih filed an action on a form complaint against Starbucks Corporation, alleging causes of action for products liability and negligence.
- Starbucks filed a motion for summary judgment or, in the alternative, for summary adjudication.
- The trial court granted Starbucks’ motion for summary judgment, ruling that Shih failed to show a triable issue of material fact regarding duty to warn, that no manufacturing defect existed, and that any alleged defect in the cup did not cause Shih’s injuries.
- Shih timely appealed the ensuing judgment from the Los Angeles County Superior Court (trial court) to the Court of Appeal of the State of California (intermediate appellate court).
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Issue:
Does the absence of a cup sleeve or a hot beverage filled to the brim constitute a proximate cause of a customer's burn injuries when the customer spills the drink after losing balance during an unorthodox attempt to sip, which involved pushing a chair and grabbing a table?
Opinions:
Majority - Segal, J.
No, the alleged defects in the cup were not a legal cause of Tina Shih's injuries. The court affirmed the trial court's grant of summary judgment, finding that Starbucks met its burden of showing the alleged defects were not a proximate cause of Shih’s injuries. While the absence of a sleeve and the full cup could arguably be a cause-in-fact (a 'but for' cause) of Shih's injuries, the connection was 'too remotely connected' and 'too attenuated' to be a legal cause. Citing Restatement (Third) of Torts, the court emphasized that a defendant's liability is limited to harms resulting from the risks that made the actor's conduct tortious, and not for harm when the tortious aspect of the conduct was not of a type that generally increases the risk of the plaintiff's harm. The specific chain of events leading to the spill—Shih losing balance, pushing her chair, grabbing the table, and knocking the cup over—was not 'within the scope of the risk' created by serving a hot beverage that is filled to the brim or lacks a sleeve. Such alleged defects do not generally increase the risk of a customer accidentally losing balance during an unorthodox drinking maneuver. Therefore, even resolving all factual disputes in Shih's favor, proximate causation was absent as a matter of law.
Analysis:
This case clarifies and reinforces the boundaries of proximate causation in California tort law, particularly in products liability and negligence actions. It emphasizes that proving cause-in-fact is not sufficient; the plaintiff must also demonstrate that the injury suffered falls within the scope of the risks generally created or increased by the defendant's alleged tortious conduct or product defect. The ruling serves to limit liability for highly attenuated or unforeseeable chains of events, preventing defendants from being held responsible for consequences that are merely coincidental to, rather than a direct and typical result of, their actions. This precedent requires a more direct and reasonably foreseeable link between the defect/negligence and the specific harm that occurred.
