Escola v. Coca Cola Bottling Co.
Citation: 24 Cal. 2d 453 (Cal. 1944)
Facts
Gladys Escola, a waitress, was injured when a Coca-Cola bottle she was handling exploded in her hand. She could not identify the specific cause of the defect but showed that the bottles were under pressure and had been mishandled. The bottling company argued she could not establish the specific negligent act.
Issue
Can a plaintiff use res ipsa loquitur to establish a prima facie case of negligence without identifying the specific negligent act, when the defendant had exclusive control over the instrumentality of harm?
Holding
The California Supreme Court majority held that res ipsa loquitur applied because the bottle was under the defendant’s exclusive control and the accident was of the type that ordinarily does not occur absent negligence, allowing the inference of negligence. Plaintiff prevailed.
Rule
Majority: Res ipsa loquitur permits an inference of negligence when (1) the accident ordinarily would not occur without negligence, (2) the instrumentality was in defendant’s exclusive control, and (3) plaintiff did not contribute to the injury. Traynor concurrence: Manufacturers should be strictly liable in tort for defective products placed in commerce, regardless of negligence.
Significance
The case is taught primarily for Justice Traynor’s concurrence, which laid the intellectual foundation for strict products liability in the United States. Traynor argued that manufacturers, as the cheapest cost avoiders, should bear liability without requiring proof of negligence. His concurrence was adopted in Greenman v. Yuba Power Products (1963) and later codified in Restatement (Second) of Torts § 402A.