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O'Keefe Architects, Inc. v. CED Construction Partners Ltd.

Citations: 909 So. 2d 370; 2005 Fla. App. LEXIS 11835Docket: No. 5D05-651

Court: District Court of Appeal of Florida; July 29, 2005; Florida; State Appellate Court

Narrative Opinion Summary

O’Keefe Architects, Inc. appeals a non-final order that compels arbitration and stays the circuit court proceedings, which is affirmed. The court emphasizes that the timeliness of a demand for arbitration is a factual issue to be resolved through arbitration rather than by the trial court. Relevant case law supporting this principle includes CED Construction, Pembroke Industrial Park, and Alderman, indicating that expiration of the statute of limitations does not negate the necessity for arbitration. However, the court certifies a conflict with the case Reuter Recycling of Florida, Inc. v. City of Dania Beach. The decision is affirmed with concurrence from Judges Pleus, Orfinger, and Monaco.

Legal Issues Addressed

Arbitration and Timeliness of Demand

Application: The court held that issues regarding the timeliness of a demand for arbitration are factual matters that should be resolved through arbitration itself, rather than being determined by the trial court.

Reasoning: The court emphasizes that the timeliness of a demand for arbitration is a factual issue to be resolved through arbitration rather than by the trial court.

Judicial Conflict Certification

Application: The court certified a conflict with a prior decision, highlighting a divergence in legal interpretations regarding arbitration and timeliness issues.

Reasoning: However, the court certifies a conflict with the case Reuter Recycling of Florida, Inc. v. City of Dania Beach.

Statute of Limitations in Arbitration

Application: The court affirmed that the expiration of the statute of limitations does not eliminate the requirement to arbitrate disputes, as supported by relevant case law.

Reasoning: Relevant case law supporting this principle includes CED Construction, Pembroke Industrial Park, and Alderman, indicating that expiration of the statute of limitations does not negate the necessity for arbitration.