24 Cal. 2d 453, 150 P.2d 436 (Cal. 1944)
Escola v. Coca-Cola Bottling is a landmark California Supreme Court case that occupies a pivotal place in torts and products liability.
Does the doctrine of res ipsa loquitur permit a jury to infer negligence by a bottler when a glass soda bottle explodes under normal handling, even though the bottle had left the defendant's physical control prior to the accident and the bottler presented evidence of due care?
Res ipsa loquitur allows an inference of negligence when: (1) the accident is of a kind that ordinarily does not occur in the absence of negligence; (2) it was caused by an instrumentality within the defendant's control at the time of the probable negligent act; and (3) it was not due to any voluntary action or contribution by the plaintiff. The "exclusive control" requirement focuses on control at the time the negligence likely occurred, not necessarily at the moment of injury, and may be satisfied where the plaintiff shows careful handling and no reasonable opportunity for third-party tampering after the product left the defendant's control. (Concurring) A manufacturer should be held strictly liable in tort when it places a product on the market, knowing it will be used without inspection, and the product proves to have a defect that causes injury.
Yes. The court affirmed the judgment for the plaintiff, holding that res ipsa loquitur applied to permit the jury to infer negligence by the bottler from the unexplained explosion of the bottle under ordinary handling.
Escola is a cornerstone case for two reasons. First, it is a leading exposition of res ipsa loquitur in product-related accidents, refining the "exclusive control" concept and the evidentiary inference of negligence where direct proof lies with the defendant. Second, Justice Traynor's concurrence became the intellectual foundation for strict products liability, which transformed consumer protection law by removing the need to prove negligence and focusing on product defect and causation. Law students study Escola both to master res ipsa and to understand the doctrinal and policy trajectory toward modern products liability.