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Koons Buick v. Nigh

Topic(s): Scope of Statutory Rights and Remedies
Docket: 03-377



Bradley Nigh sued the Koons Buick dealership under the Truth in Lending Act for intentionally charging him for a car feature for which he did not agree to pay. The court awarded him about $24,000. The dealership appealed and argued that the district court ignored TILA’s $1,000 damages cap. The Fourth Circuit held that a 1995 amendment to the act removed the $1,000 cap on recoveries involving loans secured by personal property. The question presented before the Supreme Court was whether, based on the 1995 amendment, parties who suffered no actual damages could recover more than the Truth in Lending Act’s original $1,000 cap. Unfortunately, the Court held that the 1995 amendment did not change the original limit on violations involving personal-property loans, reasoning that Congress intended the amendment to raise the minimum and maximum recoveries for closed-end loans secured by real property, but did not intend to remove the $1,000 cap on loans secured by personal property.

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