MAYNARD v. SNAPCHAT, INC

Christal McGee was driving over 100 miles per hour using Snapchat's Speed Filter, which lets users record and share their real-life speed, when she crashed into Wentworth Maynard's car and severely injured him. Wentworth and his wife Karen sued McGee and Snap, arguing 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 a manufacturer's duty to design safe products does not cover injuries caused by a third party's intentional misuse. The Supreme Court of Georgia disagreed. It held that Georgia law imposes a duty on manufacturers to use reasonable care to reduce foreseeable risks of harm, and that there is no blanket rule excusing manufacturers just because a third party used the product intentionally, tortiously, or in a way that harmed someone else. Because the Maynards adequately alleged Snap could foresee this risk, the case was sent back for further proceedings.

A manufacturer has a duty under Georgia decisional law 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 a third party's intentional or tortious misuse of the product caused the injury.

Manufacturers of apps and physical products in Georgia can no longer assume that a lawsuit will be thrown out simply because someone misused their product. Injured Georgians gain a clearer path to sue over foreseeably dangerous product designs, while companies may face more discovery and litigation costs before any liability question is resolved.

Reversed and remanded

1. The court explained that under Georgia's product-liability statute (O.C.G.A. § 51-1-11) and its own case law, a manufacturer has a duty to use reasonable care in selecting among alternative product designs to reduce risks of harm that are reasonably foreseeable, meaning risks a manufacturer could reasonably anticipate rather than merely imagine.
2. The court found that how a product was used (intentionally, negligently, or not at all) and who used it (the injured person or a third party) are simply factors relevant to whether a risk was foreseeable, not automatic bars to liability, relying on its earlier decision in Jones v. NordicTrack.
3. Applying that framework, the court concluded the Maynards had adequately alleged Snap could foresee the risk because they claimed Snap knew users were speeding at 100+ mph as part of a 'game,' knew of a prior crash linked to the feature, and designed the product to encourage such behavior.
4. The court rejected the Court of Appeals' reasoning that Snap's duty could never extend to harm caused by a third party's intentional, tortious misuse, finding no support for such a blanket exception in Georgia law and noting the Maynards were not asking Snap to control McGee's conduct, only to design its product reasonably.
5. The court also addressed policy arguments that recognizing this duty would flood manufacturers with lawsuits, concluding that doctrines like comparative negligence and apportionment of fault, plus the separate elements of breach and proximate cause, already limit manufacturers' exposure without needing a blanket duty exception.
6. Because the Court of Appeals had not yet reviewed the trial court's separate ruling that Snap's alleged negligence was not the proximate cause of the crash, the Supreme Court of Georgia sent the case back for the Court of Appeals to address that issue.

• Snapchat Speed Filter
• product liability
• design defect
• car crash lawsuit
• manufacturer duty of care