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.
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