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Maynardv.Snapchat, Inc.

CourtCourt of Appeals of Georgia
Docket No.A20A1218
DecidedJanuary 25, 2023
Reporter366 Ga. App. 507; 883 S.E.2d 533; 2023 Ga. App. LEXIS 37; 2023 WL 385210
JudgesDoyle, P.J.; McFadden, P.J.; Hodges, J., concurring.
Tags
CivilProducts LiabilityNegligent DesignProximate CauseIntervening Criminal ConductMotion to DismissSocial Media App DesignRipley's Believe It Or NotUnbelievable EvidenceExtreme Distances & Timelines
Case Summary

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.

Opinion

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