Kevin Joyce v. Forest River, Inc.

── Kevin Joyce v. Forest River, Inc. ── Court: Court of Appeals for the Eleventh Circuit Date: April 17, 2026 Category: NEW 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 Cam