General Motors Corp. v. Renjifo
Court: Appellate Division of the Supreme Court of the State of New York; February 25, 1996; New York; State Appellate Court
In a legal proceeding under CPLR 7503, a petitioner sought a permanent stay of arbitration related to a claim under General Business Law § 198-a (the New Car Lemon Law). The Supreme Court of Nassau County denied the petition, and this decision was affirmed on appeal. The petitioner argued that the respondent did not submit his claim for compulsory arbitration within the necessary four-year limitations period. However, the court found that the respondent's filing of a "Request for Arbitration" with the New York State Attorney-General was timely, as it occurred before the expiration of the four-year period. The court emphasized that the statute of limitations applicable in judicial proceedings also applies to arbitration. It clarified that the regulations do not require the consumer to pay the filing fee until after the Attorney-General's review of the arbitration demand. Since the arbitration request was accepted before the limitations period ended, the timing was valid despite the respondent's late payment of the filing fee. The court noted that the Lemon Law aims to provide consumers with more robust protections than manufacturers' warranties and that courts generally adopt a lenient approach regarding statutes of limitations in arbitration contexts. The conclusion affirmed the respondent's right to proceed with arbitration, as his claim was timely filed. Judge Santucci, along with Judges Krausman, Goldstein, and Florio, concurred with the decision.