Maynard v. Snapchat, Inc

Summary

The court held that a manufacturer’s negligent-design duty extends to reasonably foreseeable risks of harm, including risks arising from intentional or tortious use of a product by a third party, and is not subject to a blanket exception for such misuse. Because the Maynards adequately alleged that Snap could reasonably foresee users driving at excessive speeds to use the Speed Filter, dismissal on the ground that Snap owed no duty was erroneous. The court reversed and remanded for the Court of Appeals to address the unresolved proximate-cause grounds. Justice Bethel, dissenting, would have held that criminal conduct necessarily broke the causal chain and that no design duty extends to designing against a product’s use in crime.