In Maynard v. Snapchat, Inc.., Case No. S21G0555 (Decision March 15, 2022), the Supreme Court of Georgia considered whether an injured party could assert a product liability claim when the third-party user of the product engaged in conduct intentionally wrongful. The Georgia Supreme Court held that a complaint alleging such a claim could survive a motion to dismiss.
Mr. Maynard was injured in a traffic accident. The other party that hit Mr. Maynard’s vehicle was going over 100 miles an hour while using Snapchat’s ‘Speed Filter’ feature to record their speed and display it in a Snapchat post. Maynard alleged that Snapchat had poorly designed the feature and included inadequate user warnings. The Georgia Court of Appeals had upheld the dismissal of Maynard’s suit, finding that a manufacturer had no obligation to design a product to account for the intentional misconduct of a user. On certiorari review, the Georgia Supreme Court found that the complaint asserted a product liability claim.
The Georgia Supreme Court noted that a product manufacturer has an obligation to protect users against reasonably foreseeable risks of harm. By applying a risk/benefit balancing test, a manufacturer had an obligation to make reasonable design choices to avoid such harm. Because Maynard had pleaded that the driver’s misuse of the speed filter was reasonably foreseeable, that the speed filter was faulty, and that the defect was the immediate cause of his injury, he had adequately pleaded a tort action. due to the product.
The ruling says more about Georgia’s minimum notice pleading standard than it does about Georgia’s substantive product liability law. Mr. Maynard pleaded the required elements of a product liability claim; therefore, his complaint survived a motion to dismiss. When the case reaches the summary judgment stage and the case is better framed by the evidence of what happened, we will have a better idea of what Georgia law requires of a manufacturer when a user of product engages in intentional misconduct.
The case is available at https://www.gasupreme.us/wp-content/uploads/2022/03/s21g0555_sub.pdf