The Second Appellate District affirmed a judgment. The court held that where an automobile credit company applied a debtor’s current payment to a prior missed payment, with the result that the current month’s obligation went unpaid, the resultant accumulation of late fees did not violate the Rees-Levering Motor Vehicle Sales and Finance Act’s bar against charging more than one late fee per delinquent installment.
Robert Davis entered into a retail installment sales contract with Ford Motor Credit Company. Ford’s customary billing practice was to credit all payments first to any earlier missed payments. The result was that the current month’s payment sometimes went unpaid, triggering a late fee in addition to the one already accrued for the prior missed payment.
