Facts of the Case

Bradley Nigh bought a car from Koons Buick Pontiac GMC. Nigh later sued the dealership for intentionally charging him for a car feature for which he did not agree to pay. Nigh sued under the federal Truth in Lending Act (TILA). A federal district court awarded Nigh about $24,000. Koons Buick appealed and argued the district court ignored TILA's cap on damages to $1,000. A Fourth Circuit held that a 1995 amendment to the act removed the $1,000 cap on recoveries involving loans secured by personal property.

Question

Could parties who suffered no actual damages recover more than the Truth in Lending Act's original $1,000 cap because of subsequent amendments to the act?

Conclusion

No. In an 8-1 judgment delivered by Justice Ruth Bader Ginsburg, the Court held that a 1995 TILA amendment did not change the original limit on violations involving personal-property loans. Congress intended the amendment to raise the minimum and maximum recoveries for closed-end loans secured by real property. Congress had not sought to remove the $1,000 cap on loans secured by personal property.