Background
Plaintiff Kevin Joyce purchased a recreational vehicle from defendants Forest River and Freightliner in June two thousand twenty. The vehicle experienced persistent issues with headlights, the back-up camera, and the steering wheel. Joyce sought relief under Florida Lemon Law through arbitration, which ruled against him. He appealed to the district court, which affirmed the arbitration decision and granted summary judgment to both manufacturers. Joyce appealed to the Eleventh Circuit, arguing the district court incorrectly applied the statutory presumption standard.
The court’s reasoning
The court found that the district court erred by adding a requirement that Joyce meet a presumption under Florida Statute Section six eight one point one zero four. However, the court affirmed the summary judgment for Freightliner because Joyce failed to comply with other statutory requirements. For Forest River, the court determined that applying the correct standard revealed a genuine issue of material fact, necessitating reversal.
We find that the district court erred in adding a requirement that Joyce meet a presumption under the statute.
Opinion of the Court
What it means going forward
Manufacturers must adhere strictly to statutory standards without adding extra presumptions, and summary judgment may be reversed if the correct legal standard reveals factual disputes.