Recently, the Florida Supreme Court concluded that the Legislature intended to subject arbitration proceedings to the statute of limitations. An arbitration proceeding is an “action” broadly defined in § 95.011 to encompass any “civil action or proceeding,” including arbitration proceedings. Raymond James Financial Services, Inc. v. Barbara J. Phillips, SC11-2513 (Fla. May 16, 2013). The case came to the Florida Supreme Court for review in the form of a certified question by the Second District Court of Appeal. The Florida Supreme Court restated the question as follows:
DOES SECTION 95.011, FLORIDA STATUTES, APPLY TO ARBITRATION?
Answering the certified question in the affirmative, it was held that Florida’s statute of limitations applies to arbitration proceedings because an arbitration proceeding is within the statutory term “civil action or proceedings” found in section 95.011.