Supreme Court of Georgia Rules out Product Liability due to Third Party’s Wrongful Behavior
The Supreme Court of Georgia on March 15, 2022, decided in Maynard v. Snapchat, Inc., Case that a complaint alleging a product liability claim could survive a motion to dismiss when a third-party user of the product engaged in intentionally wrongful behavior.
In this case, Mr. Maynard filed a complaint about the injuries he suffered in a motor vehicle accident when Christal McGee rear-ended Mr. Maynard’s vehicle while driving over 100 miles per hour. In an inquiry, it was found that Ms. McGee was using a “Speed Filter” feature of the Snapchat app to estimate her speed and wanted to post it on her social media apps including Snapchat. Mr. Maynard alleged in his complaint that such applications are poorly designed and neglect user warnings.
However, 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. [See Maynard v. Snapchat, Inc., 357 Ga. App. 496, 500, 502 (851 SE2d 128) (2020)]. In addition to this, the Supreme Court of Georgia in its certiorari review concluded that the complaint stated a product liability claim.
The Supreme Court of Georgia stated that it is the duty of every product manufacturer to provide adequate information regarding the product and protect users against any kind of harm. The manufacturers are also obliged to invent sensible designs to avoid such harm.
The court’s decision says more about Georgia’s minimal notice pleading standard than about Georgia’s substantive product liability law. Mr. Maynard rightly 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. Therefore, his complaint survived a motion to dismiss.
Further, the supreme court of Georgia also mentioned that when the case reaches the summary judgment stage, and the case is better framed by the evidence of what happened, they will have a clear idea about what Georgia law needs from a manufacturer when a product user engages in intentional misbehavior.
Research and Writing By: Team Draft n Craft
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