MAYNARD v. SNAPCHAT, INC
S21G0555
| Ga. | Mar 15, 2022Background
- On Sept. 10, 2015, Christal McGee, driving ~107 mph, rear-ended Wentworth Maynard while using Snapchat’s Speed Filter to record and share her speed. Wentworth suffered serious injuries.
- Wentworth and his wife Karen sued McGee and Snapchat, Inc. (Snap), alleging Snap negligently designed the Speed Filter that incentivized speeding and failed to address known misuse; they sought damages and punitive relief.
- Snap relied on its Terms of Use and an in-app pop-up warning (“Please, DO NOT Snap and drive”), and moved to dismiss for failure to state a claim and for judgment on the pleadings.
- The trial court dismissed the negligent-design claim (holding Snap owed no duty and that McGee’s conduct was a superseding cause); a divided Court of Appeals affirmed, holding no duty for third-party intentional misuse.
- The Georgia Supreme Court granted certiorari, held that Georgia law does not create a blanket exception for intentional or third‑party misuse, and reversed the Court of Appeals as to duty—finding plaintiffs adequately alleged that the Speed Filter’s particular risk was reasonably foreseeable—remanding for further proximate-cause analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a manufacturer owes a decisional-law negligent-design duty to use reasonable care in selecting designs to reduce reasonably foreseeable risks from its product | Maynards: Yes — Snap owed a duty to reduce foreseeable risks posed by the Speed Filter | Snap: No duty to prevent another’s dangerous driving or to control third-party conduct | Court: Yes; duty exists where particular risk was reasonably foreseeable |
| Whether intentional misuse by a product user creates a per se exception to manufacturer’s design duty | Maynards: No per se exception; foreseeability controls regardless of intent | Snap: Intentional misuse bars a design duty for the manufacturer | Court: No blanket intentional‑misuse exception; foreseeability remains the test |
| Whether third‑party use (tortious or intentional) of a product forecloses manufacturer liability | Maynards: Manufacturer may owe duty even when a third party caused the injury if risk was foreseeable | Snap: No duty to persons injured by a third party’s use; would impose duty to control others | Court: No categorical bar; third‑party use is relevant to foreseeability, breach, and proximate causation but does not automatically negate duty |
| Whether the pleaded facts establish proximate causation or whether third‑party criminal/tortious conduct is a superseding intervening cause as a matter of law | Maynards: Allegations that Snap’s design encouraged speeding render causation plausible | Snap: McGee’s criminal/negligent driving and violation of warnings/terms supersede any design defect | Court: Did not decide causation on merits; remanded to Court of Appeals to address proximate-cause issues on the record |
Key Cases Cited
- Jones v. NordicTrack, Inc., 274 Ga. 115 (manufacturer design duty focuses on foreseeability of risk regardless of "use")
- Banks v. ICI Americas, Inc., 264 Ga. 732 (overview of strict products liability and risk-utility test for design defects)
- Johnson v. Avis Rent A Car Sys., LLC, 311 Ga. 588 (definition of proximate cause as "not unlikely" and intervening causes doctrine)
- Certainteed Corp. v. Fletcher, 300 Ga. 327 (manufacturer design duty can extend to injuries caused by third-party handling/exposure)
- Ogletree v. Navistar Int’l Transp. Corp., 271 Ga. 644 (manufacturer can be liable when a third party’s operation activates a defect causing harm)
- Pearson v. Tippmann Pneumatics, Inc., 281 Ga. 740 (both third party and manufacturer may bear liability where design allegedly misled user about safety mechanism)
- Richmond & D. R. Co. v. Dickey, 90 Ga. 491 (historic articulation that duty extends only to reasonably foreseeable risks)