Today, the Court of Appeals for the Fourth Circuit issued the opinion in Davidson v UACC, finding that the financing of ancillary products in a vehicle finance contract did not bring an otherwise excluded contract under the Military Lending Act.

The Military Lending Act regulates lenders when they extend “consumer credit” to members of the military. Yet the Act makes an exception. If the loan is “procured in the course of purchasing a car . . . when that loan is offered for the express purpose of financing the purchase and is secured by the car” then it is not “consumer credit.” 10 U.S.C. § 987(i)(6) (emphasis added). So if a member of the military takes out a secured loan to purchase a car, then the exception is satisfied and the Act does not apply. But what happens when the loan finances both the car and some related costs? Is the statute’s exception contingent on the loan financing solely the purchase of the car—i.e., is the dual-purpose loan no longer offered for the express purpose of financing the car? The district court said no and we agree. If a loan finances a car and related costs, then it is for the express purpose of financing the car purchase and the exception can apply.

The Court of Appeals for the Fourth Circuit affirmed the District Court’s ruling in favor of the automobile finance company.

A statutory provision must be given the ordinary meaning it had when it was enacted. Relevant dictionaries, carefully considered, sometimes shed light on that ordinary meaning. Yet here dueling dictionaries provide more than one linguistically permissible meaning. So we must dig deeper. Not by following the dissent’s well-intentioned descent into purposive spirit. See Holy Trinity v. United States, 143 U.S. 457 (1892). But by examining the relevant phrase in its statutory context. This context shows that while “the express purpose” can be used in different senses, it is best read in § 987(i)(6) to mean the specific purpose. This loan was offered for the specific purpose of financing Davidson’s car purchase. And that satisfies § 987(i)(6)’s relevant condition and the Act is inapplicable.