reasonable time after claim (Florida) · Go Syfert
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reasonable time after claim in Florida

8 Florida opinions name it 3 courts 1968–2011 0 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
In re the Arbitration between the County of Rockland & Primiano Construction Co.green
ny · 1980 · cited in 3 Florida opinions naming this issue, 1982–1999
2 sentences

1999This Court adopted the result of the New York decision in County of Rockland v. Primiano Construction Co., 51 N.Y.2d 1 , 431 N.Y.S.2d 478 , 409 N.E.2d 951 (1980), that found that the provision requiring a demand for arbitration within a reasonable time after the claim has arisen was not a condition precedent to arbitration but only a procedural stipulation with respect to the conduct of the arbitration proceeding and that as such, it was for the arbitrator to decide whether the demand was timely.

1999This Court adopted the result of the New York decision in County of Rockland v. Primiano Construction Co., 51 N.Y.2d 1 , 431 N.Y.S.2d 478 , 409 N.E.2d 951 (1980), that found that the provision requiring a demand for arbitration within a reasonable time after the claim has arisen was not a condition precedent to arbitration but only a procedural stipulation with respect to the conduct of the arbitration proceeding and that as such, it was for the arbitrator to decide whether the demand was timely.

23
Alderman v. City of Jacksonvillegreen
fladistctapp · 2005 · cited in 1 Florida opinions naming this issue, 2006–2006
1 sentence

2006In contrast, "[m]ere delay creating untimeliness is distinct from the active participation that creates waiver." Alderman v. City of Jacksonville Fire & Rescue Div., 902 So.2d 885, 887 (Fla. 1st DCA 2005). [5] The Second District set forth the relevant provisions: The contract contained a provision requiring the parties to arbitrate "[a]ll claims, disputes and other matters . . . arising out of, or relating to, the Contract Documents or the breach thereof." It further provided that a demand for arbitration shall be made within a reasonable time after the claim has arisen, "and in no event shal

11
PUBLIC HEALTH, ETC. v. MR Harrison Const.green
fladistctapp · 1982 · cited in 1 Florida opinions naming this issue, 1999–1999
2 sentences

1999Harrison Construction Corp., 415 So.2d 756, 757 (Fla. 3d DCA 1982), review denied, 427 So.2d 737 (Fla.1983), the county contended that Harrison did not, as required by the contract, demand arbitration "within a reasonable time after the claim, dispute or other matter in question has arisen," and thus was not entitled to enforce its right to arbitrate.

1999Public Health Trust, 415 So.2d at 758 .

11
Regency Group, Inc. v. McDanielsgreen
fladistctapp · 1994 · cited in 1 Florida opinions naming this issue, 1995–1995
1 sentence

1995"The agreement of the parties determines the issues subject to arbitration." Regency Group, Inc. v. McDaniels, 647 So.2d 192, 193 (Fla. 1st DCA 1994) (citation omitted).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
O'Keefe Architects v. Ced Const. Partners green
fla · 2006
1 sentence

2011In no event shall the demand for arbitration be made after the date when institution of legal or equitable proceedings based on such claim ... would be barred by the applicable statute of limitations.” Id. at 184 .

12011–2011
Stinson-Head, Inc. v. City of Sanibel green
fladistctapp · 1995
1 sentence

2006In contrast, "[m]ere delay creating untimeliness is distinct from the active participation that creates waiver." Alderman v. City of Jacksonville Fire & Rescue Div., 902 So.2d 885, 887 (Fla. 1st DCA 2005). [5] The Second District set forth the relevant provisions: The contract contained a provision requiring the parties to arbitrate "[a]ll claims, disputes and other matters . . . arising out of, or relating to, the Contract Documents or the breach thereof." It further provided that a demand for arbitration shall be made within a reasonable time after the claim has arisen, "and in no event shal

12006–2006
REUTER RECYCLING OF FL. INC. v. City of Dania Beach green
fladistctapp · 2003
1 sentence

2006Reuter Recycling, 859 So.2d at 1273 . [4] The parties agree that a valid written agreement exists and that the underlying claims are subject to arbitration.

12006–2006
Bickerstaff v. Frazier green
fladistctapp · 1970
1 sentence

1983The court then found that Graham Contracting's demand for arbitration made ten months later was not made within a reasonable period of time, relying on Lyons v. Krathen, 368 So.2d 906 (Fla. 3d DCA 1979), cert. den., 378 So.2d 346 (Fla. 1979), and Bickerstaff v. Frazier, 232 So.2d 190 (Fla. 1st DCA 1970), cert. dismissed, 238 So.2d 110 (Fla. 1970).

11983–1983
Lyons v. Krathen green
fladistctapp · 1979
1 sentence

1983The court then found that Graham Contracting's demand for arbitration made ten months later was not made within a reasonable period of time, relying on Lyons v. Krathen, 368 So.2d 906 (Fla. 3d DCA 1979), cert. den., 378 So.2d 346 (Fla. 1979), and Bickerstaff v. Frazier, 232 So.2d 190 (Fla. 1st DCA 1970), cert. dismissed, 238 So.2d 110 (Fla. 1970).

11983–1983
Tripi v. State neutral
fla · 1970
1 sentence

1983The court then found that Graham Contracting's demand for arbitration made ten months later was not made within a reasonable period of time, relying on Lyons v. Krathen, 368 So.2d 906 (Fla. 3d DCA 1979), cert. den., 378 So.2d 346 (Fla. 1979), and Bickerstaff v. Frazier, 232 So.2d 190 (Fla. 1st DCA 1970), cert. dismissed, 238 So.2d 110 (Fla. 1970).

11983–1983
Thorn v. Florida Real Estate Commission green
fladistctapp · 1962
1 sentence

1968To the same effect is Thorn v. Florida Real Estate Commission, (Fla.App. 2nd Dist., 1962) 146 So.2d 907, 910 , wherein that court said — Administrative officers, boards or commissions who are required to make a determination upon or after a hearing, in the exercise of a judicial or quasi-judicial function, cannot act on their own information.

11968–1968

Where else courts name it

NY 12 (1981–2025) FL 8 (1968–2011) TX 6 (1907–2015) PA 5 (1963–1975) UT 4 (2004–2013) LA 4 (1987–2016) OK 3 (1989–2006) DC 3 (1982–1993) MD 3 (1986–2019) OH 2 (2000–2000) ID 2 (2020–2020) NC 2 (1986–1991) CA 2 (1949–1992)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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