Kevin Joyce purchased an RV from Lazy Days RV on June 16, 2020. Forest River manufactured the vehicle components, while Freightliner Custom Chassis Corporation manufactured the chassis. Joyce drove the RV from Florida to Massachusetts, where it developed persistent problems with the headlights, back-up camera, steering wheel, and living facilities.
The vehicle spent 37 days at Camping World, an authorized Forest River service agent, and 55 days at Lazy Days for repairs. Joyce refused several repair offers from Forest River in 2021. He eventually sent Motor Vehicle Defect Notices to both manufacturers in February 2022.
Joyce submitted his dispute to arbitration under Florida Statute § 681.1095. The arbitration board found in favor of the manufacturers, ruling that Joyce failed to establish entitlement to a refund under Florida Lemon Law. Joyce appealed to state court, and the manufacturers removed the case to the Southern District of Florida. The district court affirmed the arbitrator's decision and granted summary judgment for both manufacturers.
The district court held that Joyce failed to carry his burden of proof by not establishing a statutory presumption regarding the number of repair attempts or out-of-service days.
The Eleventh Circuit held that the district court erred by adding a requirement that Joyce meet a presumption under the statute. The court noted that even with this error, summary judgment for Freightliner was proper because Joyce failed to comply with other statutory requirements.
However, the court reversed the summary judgment for Forest River. It held that when using the correct standard, there was a genuine issue of material fact precluding summary judgment. This conclusion stood even though the district court had properly deemed Forest River's facts as admitted due to Joyce's failure to comply with local rules.