MAYNARD v. SNAPCHAT, INC

Christal McGee was driving over 100 miles per hour while using Snapchat's Speed Filter, which lets users record their real-life speed to share, when she crashed into Wentworth Maynard's car and severely injured him. Wentworth and his wife Karen sued McGee and Snap Inc., claiming Snap negligently designed the Speed Filter knowing it encouraged dangerous high-speed driving. A trial court dismissed the claim against Snap, and the Court of Appeals of Georgia agreed, ruling that manufacturers owe no duty to people hurt by a third party's intentional, tortious misuse of a product. The Supreme Court of Georgia disagreed. It held that Georgia law imposes a duty on manufacturers to use reasonable care to reduce reasonably foreseeable risks of harm, and that neither intentional misuse, third-party use, nor tortious third-party use automatically wipes out that duty. Because the Maynards adequately alleged Snap could foresee the danger, the court reversed and sent the case back for further proceedings, including unresolved questions about proximate cause.

A manufacturer owes a decisional-law duty to use reasonable care in choosing among alternative designs to reduce reasonably foreseeable risks of harm, and this duty is not automatically eliminated just because the harm arose from a third party's intentional or tortious misuse of the product; foreseeability, not the nature of the use, controls.

The ruling means Georgia app makers and other manufacturers cannot automatically escape lawsuits just because a customer misused their product illegally or intentionally. Injured Georgians gain a clearer path to sue over dangerous product designs, while companies may face more litigation and discovery costs before cases are resolved.

Judgment reversed and case remanded with direction

1. The court explained that under Georgia's product-liability statute (O.C.G.A. § 51-1-11) and under case law, a manufacturer must use reasonable care in choosing among alternative designs, but this duty only covers risks of harm that are reasonably foreseeable, meaning risks a manufacturer could realistically anticipate.
2. The court found that the Maynards' complaint plausibly alleged Snap could foresee the risk because Snap allegedly knew users were speeding to hit 100 mph as part of a Snapchat 'game,' knew of at least one prior crash tied to similar use, and still designed the Speed Filter to encourage such use.
3. The court rejected the Court of Appeals' rule that a manufacturer's design duty never covers harm from a third party's intentional or tortious misuse, holding that its own precedent (Jones v. NordicTrack) shows duty turns on foreseeability of the risk, not on how or by whom the product was used.
4. The court clarified that intentional or tortious third-party misuse can still matter, but only as a factor feeding into whether the harm was foreseeable (duty), whether the manufacturer's design choice was reasonable (breach), or whether the misuse was an unforeseeable intervening act breaking the chain of causation (proximate cause), not as an automatic bar to any claim.
5. Because the Court of Appeals never reached the trial court's separate ruling that McGee's reckless driving was a superseding cause breaking the chain of causation, the Supreme Court of Georgia sent the case back for the Court of Appeals to decide that unresolved proximate-cause issue.

• Snapchat Speed Filter
• car crash lawsuit
• product design defect
• manufacturer duty
• distracted driving