The Florida Supreme Court held that the state’s statute of limitations that is applicable to a “civil action or proceeding” applies not only to judicial actions, but also to arbitration claims. Raymond James Fin. Services, Inc. v. Phillips,No. SC11-2513 (Fla. May 16, 2013). The court based its ruling on the language of the statute of limitations and application of principles of statutory construction, concluding that an arbitration proceeding is within the statutory term “civil action or proceeding.”