Kevin Joyce v. Forest River, Inc.

CourtCourt of Appeals for the Eleventh Circuit
DecidedApril 17, 2026
Docket24-12819
StatusPublished

This text of Kevin Joyce v. Forest River, Inc. (Kevin Joyce v. Forest River, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kevin Joyce v. Forest River, Inc., (11th Cir. 2026).

Opinion

USCA11 Case: 24-12819 Document: 55-1 Date Filed: 04/17/2026 Page: 1 of 17

FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-12819 ____________________

KEVIN JOYCE, Plaintiff-Appellant, versus

FOREST RIVER, INC., FREIGHTLINER CUSTOM CHASSIS CORPORATION, Defendants-Appellees. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 9:23-cv-81262-RLR ____________________

Before JORDAN, LAGOA, and WILSON, Circuit Judges. WILSON, Circuit Judge: In June 2020, Plaintiff-Appellant Kevin Joyce purchased a Recreational Vehicle (RV) from Defendants-Appellees Forest River Inc. (Forest River) and Freightliner Custom Chassis Corporation USCA11 Case: 24-12819 Document: 55-1 Date Filed: 04/17/2026 Page: 2 of 17

2 Opinion of the Court 24-12819

(Freightliner) (collectively, the manufacturers). Problems with the vehicle developed immediately and persisted for almost two years. Ultimately, Joyce took his claims to arbitration for relief under Florida Statute § 681.104, commonly known as Florida’s Lemon Law. The arbitration board found in the manufacturers’ favor, find- ing that Joyce failed to establish his entitlement to a refund under Florida Lemon Law. Joyce appealed that decision to the district court under Florida Statute § 681.1095(10)-(11). The district court affirmed the arbitration board. Joyce appealed the decision, arguing that the district court erred in requiring him to establish a presump- tion under Florida Statute § 681.104(3) and erred in finding no gen- uine issues of material fact based on the record. After careful review and with the benefit of oral argument, we find that the district court erred in adding a requirement that Joyce meet a presumption under the statute. Yet even with this er- ror, we affirm the district court’s decision that Freightliner was en- titled to summary judgment because Joyce failed to comply with other statutory requirements. But as to Forest River, the district court’s error in adding a requirement necessitates reversal. When using the correct standard, there is a genuine issue of material fact precluding summary judgment, even with the district court properly deeming Forest River’s facts as admitted. I. Background a. Factual History On June 16, 2020, Joyce purchased an RV from Lazy Days RV in Wildwood, Florida. Forest River is the manufacturer USCA11 Case: 24-12819 Document: 55-1 Date Filed: 04/17/2026 Page: 3 of 17

24-12819 Opinion of the Court 3

responsible for every part of the RV except the vehicle frame, known as the chassis. Freightliner is the manufacturer responsible for the chassis. Before purchasing the RV, Joyce was aware of issues with the back-up camera and steering wheel. Despite these issues, he purchased the RV and drove it from West Palm Beach, Florida, to his home in Boston, Massachusetts. During this drive, both headlights failed. On July 15, 2020, Joyce took the RV to Camping World, an authorized service agent of Forest River, to address issues with the headlights, back-up camera, and living facilities. The RV remained at Camping World until August 21, 2020, for thirty-seven days. For- est River then instructed Joyce to bring the RV to Lazy Days in Florida for repair on the steering wheel, back-up camera, wind- shield leak, chassis, living facility components, and more. On Sep- tember 10, 2020, Joyce delivered the RV to Lazy Days. The RV re- mained in Forest River’s possession until November 4, 2020, for fifty-five days. On November 4, 2020, Lazy Days sent the RV to a Freightliner service shop for chassis work on the illuminated check engine light, where it was repaired after eight days of work. On January 13, 2021, Forest River called Joyce and offered to bring the RV to their Indiana location for repairs. Joyce declined. In June 2021 and November 2021, Forest River again offered to re- pair the RV, and Joyce refused to authorize the repair. Then, in De- cember 2021, Joyce’s attorney sent a demand letter to Forest River, prompting them to offer to bring the RV in for repair for a fourth USCA11 Case: 24-12819 Document: 55-1 Date Filed: 04/17/2026 Page: 4 of 17

4 Opinion of the Court 24-12819

time. Instead, Joyce sent Forest River and Freightliner Motor Vehi- cle Defect Notices, as required by statute, in February 2022. On February 14, 2022, Forest River serviced the RV in Indi- ana, working on the back-up cameras, living facilities, and other issues for a total of 22 days. On March 3, 2022, Lazy Days sent the RV to Freightliner to address a recall and illuminated check engine light for a total of five days. Finally, on April 21, 2022, Freightliner worked on the RV for the last time to address the valve stem stabilizers, illuminated check engine light, and an active low coolant for a total of five days. Since then, Joyce has not provided Forest River or Freightliner with the RV to complete any further repairs. b. Procedural History Joyce submitted his dispute with Forest River and Freight- liner to arbitration pursuant to Florida Statute § 681.1095. After a hearing, the arbitrator found that Joyce had not met his burden of eligibility for a refund and ordered limited repairs on the RV. Joyce timely appealed to the state court, after which the manufacturers removed the case to the Southern District of Florida. After discovery, the manufacturers moved for summary judgment and filed Statements of Material Facts in support of their motions. The manufacturers argued against Joyce’s statutory enti- tlement to a refund for his RV because of his failure to meet or exceed the statutory presumption of when “a reasonable number of attempts have been undertaken to conform a motor vehicle to the warranty.” USCA11 Case: 24-12819 Document: 55-1 Date Filed: 04/17/2026 Page: 5 of 17

24-12819 Opinion of the Court 5

The district court granted summary judgment for both man- ufacturers, affirming the arbitrator’s decision. As to Forest River, the district court held that Joyce failed to carry his burden of proof in establishing a statutory presumption for when a refund or re- placement is available. Forest River argued that the RV was ser- viced only three times and “not the minimum of four occasions for the same nonconformity required by the statutory presumption.” Nor had Joyce calculated the number of out-of-service days the RV sustained for issues covered by the Lemon Law. The court found that Joyce did not properly respond to Forest River and identify the nonconformities or the isolated out-of-service days. As to Freightliner, the court also found that Joyce failed to carry his burden of proof to show that the RV had been subject to a reasonable number of attempted repairs. Because Joyce did not take the RV to an authorized Freightliner repair shop for the same nonconformity at least four times or accumulate at least sixty out- of-service days, the court found that Joyce did not “establish[] the statutory presumption for entitlement for a refund or repair.” Joyce timely appealed. II. Statement of Material Facts Joyce argues that the district court abused its discretion in enforcing the requirements of Local Rule 56.1 and deeming the manufacturers’ Statements of Material Facts admitted. “We review a district court’s application of its local rules for an abuse of discre- tion.” United States v. McLean, 802 F.3d 1228, 1233 (11th Cir. 2015). USCA11 Case: 24-12819 Document: 55-1 Date Filed: 04/17/2026 Page: 6 of 17

6 Opinion of the Court 24-12819

“The district court’s interpretation of its own rules is entitled to great deference, and the challenging party bears the burden of showing that the district court made a clear error of judgment.” Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Stewart v. Happy Herman's Cheshire Bridge, Inc.
117 F.3d 1278 (Eleventh Circuit, 1997)
Jones v. United Space Alliance, L.L.C.
494 F.3d 1306 (Eleventh Circuit, 2007)
BMW of North America, Inc. v. Singh
664 So. 2d 266 (District Court of Appeal of Florida, 1995)
Murphy v. 24th Street Cadillac Corp.
727 A.2d 915 (Court of Appeals of Maryland, 1999)
United States v. David McLean
802 F.3d 1228 (Eleventh Circuit, 2015)
Mata Chorwadi, Inc. v. City of Boynton Beach
66 F.4th 1259 (Eleventh Circuit, 2023)
Elkin King v. Forrest King, Jr.
69 F.4th 738 (Eleventh Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Kevin Joyce v. Forest River, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/kevin-joyce-v-forest-river-inc-ca11-2026.