## Facts

- On February 4, 2000, Bradley Nigh attempted to purchase a used 1997 truck from Koons Buick Pontiac GMC, Inc.
- The purchase was arranged through a retail installment sales contract requiring disclosures governed by the Truth in Lending Act (TILA), 15 U.S.C. § 1601 et seq.
- Koons had trouble obtaining third-party financing for the deal and twice revised the installment contract terms while seeking approval.
- The final paperwork stated an amount financed and a finance charge that yielded a “twice the finance charge” figure of $24,192.80.
- On October 3, 2000, Nigh sued Koons in federal court, alleging TILA disclosure violations and seeking statutory damages under 15 U.S.C. § 1640(a)(2)(A).
- Nigh requested statutory damages equal to twice the finance charge ($24,192.80), arguing that the 1995 amendment to § 1640(a)(2)(A) removed the prior $1,000 ceiling for individual actions involving personal-property transactions.
- Koons argued that, for this type of transaction, statutory damages remained subject to the long-standing $100 minimum and $1,000 maximum for “liability under this subparagraph.”
- The district court found a TILA violation and awarded Nigh $24,192.80 in statutory damages.
- A divided Fourth Circuit affirmed, reading the post-1995 text as allowing uncapped “twice the finance charge” awards for personal-property loans.
- The Supreme Court granted certiorari to decide how the 1995 amendment affected the statutory-damages limits for individual TILA actions.

## Issues

1. Whether Congress’s 1995 amendment to 15 U.S.C. § 1640(a)(2)(A) removed the $1,000 maximum on statutory damages in an individual TILA action involving a credit transaction secured by personal property.
2. Whether the phrase “except that the liability under this subparagraph shall not be less than $100 nor greater than $1,000” continued to limit damages under clause (i) (twice the finance charge), notwithstanding its placement after clause (ii) (consumer leases) in the amended text.

## Decision

- The Supreme Court reversed the Fourth Circuit and remanded.
- The Court held that the 1995 amendment did not eliminate the $100 minimum and $1,000 maximum for individual actions under § 1640(a)(2)(A) involving personal-property credit transactions.
- The Court read the 1995 addition of clause (iii)—which created a separate $200–$2,000 range for certain closed-end, real-property- or dwelling-secured transactions—as raising limits for that specific category, not as authorizing uncapped awards for personal-property loans.
- Because Nigh’s claim fell under the general “twice the finance charge” measure in clause (i) and was not within clause (iii)’s real-property/dwelling-secured category, the $1,000 cap applied.

## Legal Principles

- In an individual TILA action governed by 15 U.S.C. § 1640(a)(2)(A)(i) (twice the finance charge), statutory damages are generally limited to a minimum of $100 and a maximum of $1,000 for consumer loan transactions outside the special real-property/dwelling category.
- The 1995 amendment adding § 1640(a)(2)(A)(iii) created a distinct damages range ($200–$2,000) for certain closed-end transactions secured by real property or a dwelling; it did not silently remove the existing cap for other transactions.
- When statutory wording creates uncertainty after amendments, courts may read the provision in light of its development over time, prior judicial treatment, and the evident focus of the amendment, rather than treating a drafting placement choice as a sweeping change.
- Courts should be slow to infer a large expansion of statutory liability from a technical drafting revision when Congress’s targeted change can be implemented without discarding long-used limits for other categories.

## Conclusion

The Supreme Court held that TILA’s 1995 amendment did not authorize uncapped “twice the finance charge” statutory damages for individual actions involving personal-property credit transactions; instead, the long-standing $100 minimum and $1,000 maximum continued to apply, and the Fourth Circuit’s contrary judgment was reversed and remanded.


Koons Buick Pontiac GMC, Inc. v. Nigh, 543 U.S. 50, 125 S. Ct. 460, 160 L. Ed. 2d 389 (2004)