The court of appeals reversed a district court judgment and remanded the action for further proceedings. The court held that a consumer was not required to offer evidence of detrimental reliance to support an award of actual damages resulting from a credit card company’s violations of the federal Fair Credit Billing Act. The court held further that the consumer was not limited to recovery of a single statutory penalty where the card issuer’s violations fell outside the Act’s “single recovery” provision pertaining to disclosure-related violations.
Barbee Lyon notified Chase Bank USA, N.A., when his Visa credit card was stolen. While coordinating with Chase’s fraud department, Lyon verified that a pending $645 charge to his card was authorized and valid. When Chase refused to make payment on the charge, Lyon made separate arrangements to pay the debt.
