In Dixon v. AmeriCredit Fin. Servs., No. 19-30123, 2019 U.S. App. LEXIS 20319 (5th Cir. July 9, 2019), the Court of Appeals held that GM Financial’s repossession was proper.
GM Financial submitted the following unrebutted summary-judgment evidence showing it complied with these requirements before repossessing Dixon’s car: Dixon’s car lease—proving that it was a month-to-month lease. Dixon’s payment record—establishing that he missed both the April and May payments in 2015. And a letter sent to Dixon in November 2015 to the same address where GM Financial repossessed Dixon’s car a year later—proving that GM Financial informed him of his default and warned him of its intent to repossess if the default was not cured.1 Dixon never made the payments. Dixon seems to think that he has a valid claim because he was in default for only 55 days. If Dixon’s lease required payments to be made more frequently than on a monthly basis, he may be correct. But as explained, Dixon’s car lease is a monthly lease, and he can [*4] therefore be in default by missing two payments—even if the two months add up to less than 60 days.