On January 25, 2023, the Court of Appeals of Georgia issued an opinion in Maynard v. Snapchat, Inc. reversing the trial court’s dismissal of the case on proximate cause grounds. The Court held that “[b]ecause the Maynards’ complaint alleged facts that, if proven, sufficiently demonstrate that Snap’s negligent design proximately caused the Maynards’ injuries, we now reverse the trial court’s judgment granting Snap’s motion to dismiss on proximate cause grounds.” Opinion at p. 3.
The Court explained, “[b]ased on these facts as alleged, a finder of fact could infer that Snap’s Speed Filter was a proximate cause of the collision. Opinion at p. 6. The reasoning of the Georgia Court of Appeals is similar to that applied by the Honorable Michael W. Fitzgerald of the United States District Court for Central District of California in another case involving against Snapchat related to its Speed Filter – Lemmon v. Snap. – and also involving Neff Injury Law and co-counsel Bondurant Mixson and Elmore. There, Judge Fitzgerald found that the Plaintiffs adequately alleged that the design of Snapchat’s Speed Filter encouraged reckless driving and, thus, have properly pled proximate causation.
Snapchat has been criticized for creating and promoting a “Speed Filter” to its users who are primarily teenagers and young adults. Educational Psychologist and University of Louisiana Lafayette Professor T. Scott Smith has pointed out that teenagers and young adults accept risky behaviors to gain popularity on social media platforms. Within pleadings filed by Neff Injury Law and its co-counsel, the Plaintiffs have alleged that the Speed Filter’s design encouraged reckless driving, particularly in younger drivers.
The Georgia Court of Appeals’ ruling allows the Maynard case to return to the trial court for discovery against Snapchat. Lead Counsel for the Maynards, Michael Neff explained, “After nearly six years of litigation, the Maynard family and their lawyers are grateful to receive the Georgia Court of Appeals’ reasoned decision in their favor. The Maynard family looks forward to engaging in discovery and pursuing full justice.”