The Seventh Circuit has affirmed the dismissal of a Truth in Lending Act (“TILA”) claim in Sales v. Urankar, et al. In Sales, the plaintiff alleged that he entered into a retail installment contract for the purchase of truck that violated TILA because it was conditioned on the plaintiff’s agreement to a service contract or extended warranty. The district court dismissed the complaint.
In the Seventh Circuit, the plaintiff relied on cases involving financing conditioned on the inclusion of insurance products or service contracts which were alleged to have violated TILA because the products and contracts were not included as part of the finance charges in the TILA disclosures. The Seventh Circuit, however, rejected the plaintiff’s analogy to that line of cases, finding that the plaintiff failed to “identify any information required by TILA that defendants failed to disclose.”
The Seventh Circuit designated the Sales decision as a “Nonprecedential Decision.” Pursuant to Federal Rule of Appellate Procedure 32.1, however, federal courts may not prohibit citation to this or other similarly designated decisions.