Thigpen v. Westlake Services, LLC

Court of Appeals for the Tenth Circuit·Decided August 5, 2026·No. 25-2081·Unpublished

Opinion

FILED

United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT August 5, 2026

Christopher M. Wolpert

Clerk of Court

RICHARD THOMAS THIGPEN,

Plaintiff - Appellant,

v. No. 25-2081 (D.C. No. 1:24-CV-00214-KWR-

WESTLAKE SERVICES, LLC, SCY)

(D. N.M.)

Defendant - Appellee.

ORDER AND JUDGMENT *

Before BACHARACH, KELLY, and EID, Circuit Judges.

Mr. Thigpen bought a truck and entered a contract to pay in installments, and the seller assigned the contract to Westlake Services, LLC. Mr. Thigpen stopped paying and sued Westlake for nondisclosure and

*

Oral argument would not help us decide the appeal, so we have decided the appeal based on the record and the briefing. See Fed. R. App. P. 34(a)(2)(C); 10th Cir. R. 34.1(G).

This order and judgment is not precedential except under the doctrines of law of the case, res judicata, and collateral estoppel. But the order and judgment may be cited for its persuasive value if otherwise appropriate. See Fed. R. App. P. 32.1(a); 10th Cir. R. 32.1(A).

misconduct in collecting what he owed. The district court granted summary judgment to Westlake, and Mr. Thigpen appeals. We affirm. 1. Consideration of Westlake’s Reply Brief On appeal, Mr. Thigpen argues that the district court erred by considering arguments presented for the first time in Westlake’s reply brief. In district court, Mr. Thigpen requested leave to file a surreply brief “to address and rebut [Westlake’s] new arguments.” R. at 311. The district court allowed Mr. Thigpen to file a surreply, and he did so.

Even though Mr. Thigpen got what he requested, he argues that the district court shouldn’t have considered the arguments newly asserted in Westlake’s reply brief. We reject this argument because the court didn’t err: Mr. Thigpen asked for a chance to file a surreply, he received permission and filed the surreply, and the court considered the surreply just as he had requested. 1 2. Grant of Summary Judgment Nor did the court err in granting summary judgment to Westlake.

Mr. Thigpen asserted claims involving the Truth in Lending Act, the Fair Debt Collection Practices Act, the Telephone Consumer Protection Act,

1 Mr. Thigpen quotes the district court as saying: “Because Plaintiff’s sur-reply contains newly alleged evidence from his response, the Court will grant the sur-reply and consider the additional materials.” Appellant’s Opening Br. at 16. This language does not appear in the district court’s order.

breach of contract, unjust enrichment, and violation of the New Mexico Unfair Practices Act. a. Standard of Review We conduct de novo review of the district court’s grant of summary judgment. Birch v. Polaris Indus., Inc., 812 F.3d 1238, 1251 (10th Cir. 2015). In that review, we draw all reasonable inferences in favor of the nonmoving party (Mr. Thigpen) to determine whether Westlake was entitled to judgment as a matter of law. Id.; Fed. R. Civ. P. 56(a). b. Claims under the Truth in Lending Act Mr. Thigpen claims violation of the Truth in Lending Act, which requires a creditor to make disclosures before the borrower enters into a contract. 15 U.S.C. § 1638(a). The district court concluded that this claim was time-barred and invalid on the merits, and we agree with both conclusions. i. Timeliness For this claim, a one-year period of limitations exists, 15 U.S.C.

§ 1640(e), and Mr. Thigpen conceded in district court that the claim had accrued when he bought the truck. He repeats that concession on appeal, stating that the contract triggered the limitations period and explaining that

the later billing statements couldn’t have triggered the statute of limitations:

The [district] court misapplied equitable tolling by holding Plaintiff’s [Truth in Lending Act] claims time-barred based on billing statements. Plaintiff never received the required disclosures in the first place, so there was nothing in those statements that could have triggered the statute of limitations. Billing statements do not have [Truth in Lending Act] disclosures within them so this information should have been in the [retail installment contract].

Appellant’s Opening Br. at 20.

After signing the contract, Mr. Thigpen waited two years to sue. So the claim would ordinarily be time-barred. But he argues that (1) he was entitled to equitable tolling and (2) the violations were continuing. These arguments lack merit.

For equitable tolling, Mr. Thigpen argues that he couldn’t have discovered the violations earlier. For the sake of argument, we can assume that the limitations period is subject to equitable tolling when a debtor couldn’t reasonably discover the violation earlier. See Jones v. TransOhio Sav. Ass’n, 747 F.2d 1037, 1041 (6th Cir. 1984) (recognizing equitable tolling for claims under the Truth in Lending Act based on the debtor’s inability to discover the fraud underlying the asserted violation). But Mr. Thigpen hasn’t said why he couldn’t have compared the contractual disclosures with the statutory requirements. See Hubbard v. Fid. Fed. Bank, 91 F.3d 75, 79 (9th Cir. 1996) (concluding that the limitations

period under the Truth in Lending Act wasn’t equitably tolled because the debtor could have compared the creditor’s disclosures to the statutory and regulatory requirements). Without such an explanation, the district court didn’t err in rejecting Mr. Thigpen’s reliance on equitable tolling.

Mr. Thigpen also claims that Westlake continued to violate the statute by • sending misleading billing statements to him and • failing to disclose finance charges for the insurance.

But the Act requires disclosures before extending credit. 15 U.S.C. § 1638(a); see p. 3, above. A later billing statement might fail to cure an earlier violation. But no new violation could take place absent another extension of credit, Begala v. PNC Bank, 163 F.3d 948, 951 (6th Cir. 1998), and Mr. Thigpen doesn’t argue that the billing statements provided him with new credit. 2 Absent a basis for equitable tolling or a continuing violation, the claim is time-barred.

2 Mr. Thigpen points out that the district court didn’t discuss the possibility of a continuing violation from the billing statements. But the district court didn’t discuss this issue because Mr. Thigpen hadn’t raised it until the appeal.

ii. Adequacy of the Disclosures The district court relied not only on the statute of limitations but also on the undisputed evidence of disclosures. Mr. Thigpen argues that (1) the disclosures were inadequate, (2) the district court decided matters outside Westlake’s arguments for summary judgment, and (3) the court disregarded pertinent evidence. We reject these arguments.

Undisputed Evidence of Conspicuous Disclosures Under the Act, a creditor must clearly and conspicuously disclose the annual percentage rate, amount financed, and specific finance charge. 15 U.S.C. §§ 1632(a), 1638(a). And the contract provides these disclosures. For example, the first page of the contract contains boxes with titles in bold, labeled Truth-in-Lending Disclosure. Inside this box were the annual percentage rate, amount financed, and the finance charge.

Mr. Thigpen doesn’t explain why these disclosures would have lacked the required clarity or conspicuousness.

He does argue that Westlake failed to disclose the finance charges for insurance. But Mr. Thigpen doesn’t present any evidence that Westlake offered insurance. Westlake just told Mr. Thigpen that he needed to obtain insurance from an acceptable insurer.

Mr. Thigpen also argues that Westlake failed to tell him that he could obtain an itemization of the finance charges. But the district court explained that Westlake had provided the itemization in the contract itself, and Mr. Thigpen doesn’t identify any deficiencies in the itemization.

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