Maynard v. Snapchat, Inc.
Facts
Snapchat created a Speed Filter feature that allows users to record their speed and overlay it onto a photo or video. The complaint alleged that Christal McGee drove at an excessive speed in an attempt to capture 100 miles per hour on the Speed Filter, then rear-ended Wentworth Maynard's vehicle and injured those involved. The Maynards sued Snapchat, alleging negligent design because the feature encouraged dangerous driving. The alleged injury arose from McGee's misuse of the Speed Filter while driving.
Issue
Whether Snapchat owed the Maynards a legal duty to alter the design of its Speed Filter to prevent injuries caused when a third party used the feature while driving recklessly. More specifically, the question was whether a negligent design claim could proceed where the alleged harm was predicated on a third party's tortious misuse of the product.
Rule
A negligence claim requires a legal duty, breach, causation, and damages, and the existence of duty is a question of law for the court. Georgia recognizes no general duty to all the world to prevent unreasonable risk of harm, and as a general rule there is no duty to control the conduct of third persons absent a special relationship. Although manufacturers must exercise reasonable care to make products reasonably safe for intended or foreseeable uses, that duty does not extend, under these facts, to preventing a third party's intentional tortious misuse of a use-neutral product while driving.
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