Dawn Brown v. Tennessee Title Loans, Inc.

Summary

The Court held that the Tennessee Title Pledge Act did not create an express or implied private right of action for pledgors seeking relief for excessive interest or prohibited fees. Although pledgors were intended beneficiaries, the Act's regulatory structure, governmental enforcement mechanisms, legislative history, and later enactment of expressly authorized private actions did not make legislative intent to imply a remedy manifestly clear. The Court reversed the Court of Appeals, reinstated dismissal of the Title Pledge Act claims, and remanded for litigation of the remaining claims.