Maynardv.Snapchat, Inc.
Wentworth Maynard was catastrophically injured when another driver allegedly used Snapchat's Speed Filter while racing past 100 miles per hour and rear-ended his car, and the Maynards sued Snapchat for negligent design. After the Supreme Court of Georgia had already revived the design-duty theory, the case returned to the Court of Appeals to decide whether the complaint still failed on proximate-cause grounds because the driver's reckless conduct was an intervening cause. The Court of Appeals reversed the dismissal. It held that the complaint plausibly alleged that Snapchat's design was a proximate cause of the crash because the Speed Filter allegedly encouraged dangerous speeding and the pleaded facts tied the driver's conduct directly to her desire to post a 100-mph snap. The court reasoned that intervening misconduct does not break causation at the pleading stage when that kind of misconduct is itself a foreseeable consequence of the product design, and the complaint alleged just that.
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