Maynard v. Snapchat, Inc.

Court of Appeals of Georgia · 2020 · Torts
Updated
TortsNegligenceDutyProduct designmotion to dismissthird-party conductspecial relationshipmisuse

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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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Beacon Loop Labs released a smartphone app in Atlanta that overlays a user's real-time altitude onto photos and videos. After seeing the feature, Nolan Price intentionally sped his motorcycle down a public road in north Georgia to make the number look dramatic in a clip, then struck Dana Ibarra's car; Dana sues Beacon Loop for negligent design.

How should the court most likely rule on Beacon Loop's motion to dismiss the negligence claim?

Explanation. The majority held that duty is a threshold legal question and that Georgia recognizes no general duty to control third persons absent a special relationship. Where the injury is predicated on a third party's tortious misuse of a use-neutral app while driving, the negligent design claim fails for lack of duty even if misuse may be foreseeable. (Derived from Maynard v. Snapchat, Inc. (n.d.).)