In Maynard v. Snapchat, Inc., Case No. S21G0555 (decided March 15, 2022), the Georgia Supreme Court examined whether an injured party could assert a product liability claim when the third-party user of the product had engaged in intentionally wrongful behavior. The Georgia Supreme Court concluded that a complaint alleging such a claim could survive a motion to dismiss.
Mr. Maynard suffered injury in a traffic accident. The other party who hit Mr. Maynard’s vehicle was driving over 100 miles per hour while using the “Speed Filter” feature of Snapchat to record her speed and display it as part of a post on Snapchat. Maynard alleged that Snapchat had defectively designed the feature and included inadequate user warnings. The Georgia Court of Appeals had upheld the dismissal of Maynard’s complaint, concluding that a manufacturer had no duty to design a product to accommodate a user’s intentional misbehavior. On certiorari review, the Georgia Supreme Court concluded that the complaint stated a product liability claim.
The Georgia Supreme Court noted that a product manufacturer owed a duty to protect users against reasonably foreseeable risks of harm. Applying a risk/utility balancing test, a manufacturer bore an obligation to make reasonable design choices to avoid such harms. Because Maynard had pled that the driver’s misuse of the Speed Filter was reasonably foreseeable, that the Speed Filter was defective, and that the defect was the proximate cause of his injury, he had adequately pled a product liability claim.
The decision says more about Georgia’s minimal notice pleading standard than about Georgia’s substantive product liability law. Mr. Maynard pled 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 from a manufacturer when a product user engages in intentional misbehavior.
The case is available at https://www.gasupreme.us/wp-content/uploads/2022/03/s21g0555_sub.pdf