Koons Buick Pontiac Gmc, Inc. v. Nigh

Summary

The Court held that the Truth in Lending Act's $100 minimum and $1,000 maximum statutory damages limits continue to apply to individual actions under clause (i), including personal-property-secured loans. The 1995 amendment created a separate $200 minimum and $2,000 maximum for specified closed-end transactions secured by real property or a dwelling, but did not remove the preexisting limits for other transactions. The Court relied on the statutory hierarchy, the provision's history, and the absence of evidence that Congress intended such a substantial change. Justice Scalia, dissenting, would have treated the limitation as confined to clause (ii), while the concurring opinions agreed with the result but differed over the role of text, statutory history, and common sense.