Joyce v. Forest River, Inc.
An RV purchaser sought a refund under Florida's Lemon Law, Fla. Stat. § 681.104, after arbitration and district court rulings against him. The Eleventh Circuit held that the § 681.104(3) 'reasonable number of attempts' presumptions (three repair attempts, or 60 out-of-service days for an RV) are illustrative examples, not mandatory prerequisites to relief, and that a consumer need not isolate which nonconformities were repaired on which days to accumulate out-of-service days. It reversed summary judgment for the coach manufacturer but affirmed for the chassis manufacturer because the consumer sent his Motor Vehicle Defect Notice prematurely under Section 1.
Key facts
- RV purchaser Joyce purchased a recreational vehicle from Forest River, Inc. (coach manufacturer) and Freightliner (chassis manufacturer) and sent a Motor Vehicle Defect Notice after the RV experienced multiple nonconformities and was in repair shops for approximately 114 days.
- An arbitrator and district court ruled against Joyce's Lemon Law claim under Fla. Stat. § 681.104, granting summary judgment to both manufacturers on the ground that Joyce failed to satisfy the statutory presumptions of three repair attempts or 60 out-of-service days.
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Why it matters
This is the first published federal appellate construction of the relationship between the mandatory notice thresholds in Fla. Stat. § 681.104(1) and the 'reasonable number of attempts' presumptions in § 681.104(3), and… — full analysis with a trial
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