Rojas v. X Motorsport, Inc., 1:16-cv-07283

On Jan. 14, 2016 Rojas agreed to buy a used Volkswagen from X Motorsport; he paid $7,000 down and signed a Retail Installment Sale Contract (RISC) for the balance plus two short promissory notes.
The Standard Buyers Order (SBO) signed by Rojas stated the sale was conditioned on X Motorsport’s ability to assign the RISC to a third‑party financer and included a merger clause incorporating the RISC.
Rojas experienced mechanical problems, discussed returning the car with the dealer, and ultimately returned the vehicle Feb. 13, 2016 and received his down payment a few days later.
The parties dispute whether X Motorsport actually assigned the RISC to a third‑party financer and whether Rojas was told his financing was rejected.
Rojas sued under TILA (and previously asserted ECOA and state claims, later dismissed); the sole remaining dispute was whether the RISC disclosures violated TILA because they were illusory/conditioned.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether TILA was violated because disclosed credit terms were conditioned on dealer obtaining third‑party financing	Rojas: disclosures were illusory/bait‑and‑switch because the RISC would not remain binding unless the dealer assigned it, so the amount financed/terms were not the credit actually available	X Motorsport: disclosures accurately reflected Rojas’s legal obligations under the signed contract(s); the financing condition was disclosed	Court: No TILA violation; Janikowski controls—conditional disclosures that truthfully state legal obligations satisfy TILA
Dispositive/motion issues: cross‑motions and evidentiary challenges	Rojas sought partial summary judgment on TILA liability; objected to certain evidence	X Motorsport moved for summary judgment and to strike evidence	Court: Grants X Motorsport’s summary judgment; denies Rojas’s partial SJ; denies motion to strike as moot

Janikowski v. Lynch Ford, Inc., 210 F.3d 765 (7th Cir. 2000) (conditional financing disclosures that accurately state legal obligations do not violate TILA)
Marr v. Bank of Am., N.A., 662 F.3d 963 (7th Cir. 2011) (TILA’s purpose is meaningful disclosure of credit terms)
Hamm v. Ameriquest Mortg. Co., 506 F.3d 525 (7th Cir. 2007) (required disclosures include number, amount, and due dates of payments)
Rivera v. Grossinger Autoplex, Inc., 274 F.3d 1118 (7th Cir. 2001) (finance charge disclosure requirement under TILA)
IFC Credit Corp. v. Burton Indus., Inc., 536 F.3d 610 (7th Cir. 2008) (multiple documents executed together are read as a single instrument)
Williams v. Amazon.com, Inc., 312 F.R.D. 497 (N.D. Ill. 2015) (district court’s obligation to follow controlling Circuit precedent)