The case of Maynard v. Snapshot, Inc., Case No. A20A1218 (decided October 30, 2020), returned to the Georgia Court of Appeals. This time, the focus of the case was on an important issue of product liability law in Georgia.

The case involved a role that the popular social media app Snapchat played in an automobile accident. The app contains a “speed filter” that allows you “snap” and post a photograph that shows the speed at which the user is moving. A driver was attempting to reach the speed of 100 mph so that she could capture that speed on a photograph using the speed filter. The app user was involved in a traffic accident and litigation followed.

In the prior case, the Court of Appeals ruled that the claim against Snapchat was not barred by Section 230 of the Communications Decency Act. In the case’s second visit to the Court of Appeals, the court concluded that Snapchat was not liable for alleged negligent product design because a manufacturer has no duty to prevent people from committing torts while misusing a manufacturer’s product. A manufacturer has a duty to exercise reasonable care to design products that are reasonably safe for foreseeable uses. That duty did not include protecting the public against intentional misuse of the product in a tortious way. Looking at the particular circumstances of this case involving distracted driving, the court noted that Georgia law focused on regulating the conduct of drivers using electronic devices, not on the design of such devices.

This decision could apply in other circumstances in which deliberate product misuse is an issue. Defendants in product liability cases will cite it as setting a limit of the design responsibilities of manufacturers.

The opinion is available at

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