Deceptive Timeshare Exit Scheme - $140M Judgment and Permanent Injunction
Summary
The DOJ and State of Wisconsin obtained summary judgment against Christopher Lee Carroll in the Eastern District of Missouri for operating a deceptive timeshare exit services scheme that harmed over 11,000 consumers. The court ordered Carroll to pay over $95 million in consumer redress and over $45 million in civil monetary penalties, totaling more than $140 million. A permanent injunction bars Carroll from marketing timeshare exit services and engaging in unfair/deceptive trade practices.
What changed
The U.S. District Court for the Eastern District of Missouri granted summary judgment against Christopher Lee Carroll, finding he was the 'mastermind' of an unlawful timeshare exit enterprise. The court held Carroll liable for violating the FTC Act's prohibition on unfair/deceptive practices, the federal Cooling-Off Rule (requiring three business days to cancel purchases), and Wisconsin state fraudulent misrepresentation laws. Carroll and co-defendants used high-pressure tactics and false statements to induce consumers to pay $5,000 to over $80,000 for purported timeshare exit services at businesses including Square One Group LLC and Consumer Law Protection LLC—services often not actually provided. The judgment exceeds $140 million: over $95 million for consumer redress and over $45 million in civil penalties. The court also imposed permanent injunctions against 17 other defendants, including corporate entities jointly liable for the judgment and four individuals collectively liable for over $11 million.
Companies marketing timeshare exit or similar consumer services must immediately review their practices for compliance with the FTC Act and Cooling-Off Rule requirements. All sales contracts must include proper three-business-day cancellation disclosures and refund policies for non-delivered services. Regulators demonstrated willingness to impose substantial penalties ($45M+ civil penalties, $140M total judgment) for deceptive practices, especially those targeting elderly consumers. Compliance teams should audit marketing materials, sales scripts, and cancellation/refund procedures for any consumer-facing financial or timeshare-related services.
What to do next
- Review timeshare exit and consumer service marketing for FTC Act and Cooling-Off Rule compliance
- Ensure all sales contracts include mandatory three-business-day cancellation disclosures
- Establish refund protocols for consumers when services are not delivered
Penalties
Over $95 million in consumer redress; over $45 million in civil monetary penalties; permanent injunction prohibiting timeshare exit service marketing and unfair/deceptive trade practices; total judgment exceeds $140 million
Source document (simplified)
News
Press Release
United States and State of Wisconsin Obtain Over $140M Judgment and Permanent Injunction Against Operator of Deceptive Timeshare Exit Services Aimed at Elderly Consumers
Wednesday, April 1, 2026
Share For Immediate Release Office of Public Affairs The U.S. District Court for the Eastern District of Missouri granted summary judgment to the Department of Justice and State of Wisconsin against Defendant Christopher Lee Carroll, finding he was a “mastermind” of an unlawful timeshare exit services scheme that harmed over 11,000 consumers. As part of its ruling, the court permanently enjoined Carroll from marketing timeshare exit services and from engaging in other unfair and deceptive trade practices. The court also ordered Carroll to pay over $95 million to redress harm caused to consumers and over $45 million in civil monetary penalties for his misconduct.
“The Justice Department will hold accountable anyone who uses unlawful high-pressure sales tactics and deception to take advantage of and exploit consumers,” said Assistant Attorney General Brett A. Shumate of the Justice Department’s Civil Division. “Americans deserve to be treated fairly and honestly.”
In a memorandum and order, the district court held that Carroll was at the center of an unlawful enterprise that violated the Federal Trade Commission (FTC) Act’s prohibition on unfair or deceptive trade practices, the federal Cooling-Off Rule’s requirement that consumers be given three business days to cancel certain purchases made at locations other than the seller’s regular place of business, and Wisconsin state laws concerning fraudulent misrepresentations and direct marketing.
The court found that Carroll and his co-defendants used high pressure tactics and false and misleading statements to induce consumers to pay from $5,000 to over $80,000 to businesses including Square One Group LLC, and Consumer Law Protection LLC, for a purported release or exit from the consumers’ timeshare contracts. Carroll and his co-defendants often did not actually provide those services, did not inform consumers of their right to cancel the sales contracts within three business days without penalty, and denied consumers refunds when they or law enforcement officials complained.
Carroll was the final remaining defendant in this action. The court previously also imposed permanent injunctions against seventeen other defendants. Those defendants include several interrelated corporate entities, which were also held liable for the over $140 million monetary judgment against Carroll, and four other individual defendants, who agreed to stipulated orders under which they are collectively liable for over $11 million in monetary penalties, partially suspended due to their demonstrated inability to pay.
The United States is represented in this action by Trial Attorneys Meredith L. Reiter and Zachary L. Cowan and Assistant Director Zachary A. Dietert, from the Enforcement Section of the Civil Division’s Enforcement and Affirmative Litigation Branch, in coordination with staff at the FTC. The United States was previously also represented by former Trial Attorney Wesline N. Manuelpillai. Lewis W. Beilin represents the State of Wisconsin.
For more information about the Enforcement & Affirmative Litigation Branch and its enforcement efforts visit www.justice.gov/civil/enforcement-affirmative-litigation-branch.
Updated April 1, 2026 Component Civil Division Press Release Number: 26-307
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