In Escola v. Coca-Cola Bottling Co. of Fresno, 24 Cal. 2d 453, 150 P.2d 436 (1944), the coca cola bottle that exploded (injuring the waitress who was transferring the bottles to the refrigerator) had been out of refrigeration for"at least thirty-six hours" in Fresno, California. The case was heard (on appeal) in July, but I have not been able to find out at what time of the year the accident happened.
As evidence that courts are concerned with the problem of joint causation, consider the following passage from the opinion by Gibson, C.J.:
"As said in Dunn v. Hoffman Beverage Co., 126 N.J.L. 556 [20 A.2d 352 , 354],
"defendant is not charged with the duty of showing affirmatively that something happened to the bottle after it left its control or management; ... to get to the jury the plaintiff must show that there was due care during that period."
Plaintiff must also prove that she handled the bottle carefully. The reason for this prerequisite is set forth in Prosser on Torts, supra, at page 300, where the author states:
"Allied to the condition of exclusive control in the defendant is that of absence of any action on the part of the plaintiff contributing to the accident. Its purpose, of course, is to eliminate the possibility that it was the plaintiff who was responsible. If the boiler of a locomotive explodes while the plaintiff engineer is operating it, the inference of his own negligence is at least as great as that of the defendant, and res ipsa loquitur will not apply until he has accounted for his own conduct."