A suburban St. Paul dealership must pay the minimum penalty of $50 for failing to provide a customer with a copy of his signed sales agreement, the Minnesota Court of Appeals has ruled.
But the court increased the attorney fees and court costs awarded by a trial judge from $4,063 to $16,254.
That amount is still far below the $116,022 the customer had requested.
The case had been in federal and state courts for seven years.
In the aftermath of the decision, the parties settled for an undisclosed amount to avoid an appeal.
The dispute stemmed from Raymond Scott's 1995 purchase and financing of a new Dodge Caravan from Forest Lake Chrysler-Plymouth-Dodge in Forest Lake, Minn.
In a series of federal and state lawsuits, Scott challenged the use of a conditional delivery agreement instead of a retail installment contract and the dealership's failure to sign and deliver a contract.
Scott conceded that he suffered no "loss, damage, inconvenience or risk," the court noted.
Most of the claims were dismissed, and a Washington County District Court judge held that the dealership's technical violation had been unintentional.
He awarded the minimum $50 penalty plus attorney fees.
The unanimous appeals panel affirmed the ruling.
"The legislature did not intend that a technical violation of the statute would be used to enrich the buyer," Judge David Minge wrote.
"Here the buyer did not incur any damages or harm. He purchased the vehicle, knew its cost, knew the cost of the financing, paid those costs and drove that vehicle."
The court did disagree with the trial judge's calculation of attorney fees.
Dealership lawyer Gregory Johnson of St. Paul said he was disappointed by the attorney fees ruling but was pleased by the court's interpretation of the installment sales law.
"Hopefully, this would be a damper on those types of claims that don't involve any out-of-pocket loss to the customer," he said.
But Scott's lawyer, John Goolsby of Little Canada, Minn., said the court's interpretation leaves consumers with little incentive to pursue claims for violations because dealerships can get away with a slap on the wrist. "We are afraid," he said, "that this will permit dealerships to engage in deliberate conduct."
