Koons Buick Pontiac GMC, Inc. v. Nigh

Background

Bradley Nigh, a car buyer, sued a car dealership after discovering a $965 charge for a car alarm he never ordered. He sought statutory damages under the Truth in Lending Act equal to twice the finance charge—about $24,193. The dealership argued a $1,000 statutory cap applied. A jury awarded the full double-finance-charge amount, and the Fourth Circuit affirmed after interpreting a 1995 amendment as removing the $1,000 cap for non-real-property loans.

Reasoning

The Court addressed whether Congress's 1995 amendment, which added a clause setting $200–$2,000 for closed-end loans secured by real property, also eliminated the preexisting $100–$1,000 range for other loans. Looking at the statute's wording, drafting conventions, and the law's history, the majority concluded Congress meant only to raise limits for closed-end real-property loans and did not repeal the longstanding $100/$1,000 brackets for personal-property and most other loans. The Supreme Court reversed the Fourth Circuit and remanded for further proceedings.

Real world impact

The ruling preserves the $100 minimum and $1,000 maximum statutory damages for most consumer loans not secured by real property, while a higher $200–$2,000 range applies only to closed-end real-estate loans. This decision changes how judges and juries calculate recoveries in many consumer disclosure suits under the Act. The opinion is a final interpretation of the statute's damage rules and will guide ongoing and future cases.

Dissents or concurrances

Several Justices wrote separately: some joined the judgment but emphasized different interpretive approaches (textual, historical, or common-sense reasoning). Justice Scalia dissented, arguing the $100–$1,000 phrase should limit only the consumer-lease clause and that the Fourth Circuit should have been affirmed.