According to a contemporaneous Denver Post article, Stella Liebeck’s coffee was between 165° and 170° when it was spilled. It was other restaruants and branches where they measured hotter coffee right after it was poured.
Consumer reports has reported (year on year since the early 90’s) that most home coffeemakers hold the coffee at 175° or better. Coffeemakers meeting the ANSI standard will hold at greater than 170° The manuals that come with the commercial coffee machines suggest hold temperatures of 175°- 185°. The Specialty Coffee Association of America suggest similar hold temperatures.
So yes, the brewing will be at higher temperatures, and the closer in time to the actual brewing the hotter the coffee will be until it settles to its hold temperature. But I can find no evidence of any body that suggests typical practice is more than 2°c lower than the lawsuit’s estimate of the temperature of the coffee that caused the injury.
