TCPA research collection
The issue depends on the statutory provision, the court and the facts. This collection separates the do-not-call private action in §227(c)(5) from §227(b)’s automated-call provisions.
The texts-as-calls case map
Select a circuit or state to explore federal decisions on texts and the TCPA’s do-not-call protections. A location is a research starting point—not a verdict on your messages.
Choose a region on the map, or use the controls below. Crimson shows your selection, not whether a claim succeeds.
Territories and small states are available in the selector. The nongeographic Federal Circuit is not a regional TCPA court and is not mapped.
Each record describes an issue, not a promised outcome. Review status and opinion availability are identified individually.
Declines to follow Steidinger's exclusion of texts from §227(c)(5). September order not independently retrieved.
1:26-cv-00632, ECF 11 · p. 5 n.2
Opinion text not independently reviewed.
Denies a motion arguing that texts are outside §227(c)(5). September order not independently retrieved.
1:26-cv-20408-DPG, paperless ECF 33 · ECF 33
Opinion text not independently reviewed.
Independently interprets §227(c)(5) to encompass texts and denies dismissal. A district ruling, not binding Third Circuit precedent.
2:25-cv-15801, ECF 31 · pp. 5–8
Opinion text reviewed — automated editorial review
Concludes that texts are calls under §227(c)(5).
3:25-cv-02331-BBK; 2026 WL 2654093 · *6 (Westlaw)
Opinion text not independently reviewed.
Concludes that §227(c)(5) encompasses texts.
3:25-cv-00108, ECF 16 · pp. 13–15
Opinion text not independently reviewed.
Applies Ninth Circuit text-message precedent to §227(c) and denies dismissal. This is a district ruling, not a Ninth Circuit §227(c)(5) opinion.
3:26-cv-05017-BHS, ECF 23; 2026 WL 2017320 · pp. 4–8
Opinion text reviewed — automated editorial review
Holds texts are calls for §227(c), relying on statutory language, regulations and other decisions; denies defendant's motion to dismiss.
2:25-cv-07016, ECF 13; 2026 WL 1747214 · pp. 4–10
Opinion text reviewed — automated editorial review
Applies Howard to text messages under §227(c).
2026 WL 1708531 · *4 (Westlaw)
Opinion text not independently reviewed.
Applies Howard to text-based §227(b) and §227(c) theories. Signed April 22; reported entry date April 23. Later reconsideration order not independently inspected.
2:26-cv-01225-JAT, ECF 35; 2026 WL 1098239 · pp. 9–11
Opinion text reviewed — automated editorial review
Includes texts under §227(c)(5) through independent statutory analysis. Damages theory survives; injunctive relief is separately dismissed.
2:25-cv-05238-JFM, ECF 25; 2026 WL 927378 · pp. 9–19
Opinion text reviewed — automated editorial review
Includes texts under §227(c)(5). This classification concerns the scope issue, not the case's overall outcome.
2:25-cv-15515; 2026 WL 881651 · *6 (Westlaw)
Opinion text not independently reviewed.
Finds the ordinary meaning of telephone call encompasses texts under §227(c)(5); denies dismissal.
3:25-cv-00112-SFR, ECF 87 · pp. 8–17
Opinion text reviewed — automated editorial review
Treats texts as calls under §227(c).
2026 WL 974297 · *3 (Westlaw)
Opinion text not independently reviewed.
Includes texts under §227(c), following Alvarez's analysis; denies dismissal and a stay.
3:25-cv-00152, ECF 75; 2026 WL 413198 · pp. 4–8
Opinion text reviewed — automated editorial review
Includes texts within §227(c)(5). Dismissal is denied on that issue; injunctive-relief pleading is addressed separately.
7:25-cv-00343, ECF 42; 2026 WL 202930 · pp. 6–13
Opinion text reviewed — automated editorial review
Treats texts as actionable under §227(c)(5).
2:25-cv-01481-MTL, ECF 29 · p. 6
Opinion text not independently reviewed.
Includes texts under §227(c). An appellate docket shows a limited remand in May; no appellate merits resolution is asserted here.
5:23-cv-00281; 2026 WL 486556 · *6–7 (Westlaw)
Opinion text not independently reviewed.
Independently interprets §227(c) to include texts; denies dismissal. Relies on ordinary meaning, statutory context and privacy purpose.
1:25-cv-05503-PAE, ECF 34; 811 F. Supp. 3d 631 · pp. 8–16
Opinion text reviewed — automated editorial review
Allows text-based §227(c) claims. Restrictive textual reasoning quoted by other courts must not be confused with the operative result. Interlocutory-review status not independently established.
2:25-cv-05093-JLS-BFM; 2025 WL 3549868 · 2025 WL 3549868
Opinion text not independently reviewed.
Includes texts under the do-not-call provisions. Later arbitration rulings are different issues.
2025 U.S. Dist. LEXIS 231053 · LEXIS 231053
Opinion text not independently reviewed.
Includes texts under the do-not-call provisions.
2025 U.S. Dist. LEXIS 231061 · LEXIS 231061
Opinion text not independently reviewed.
Treats texts as actionable under §227(c)(5).
3:25-cv-00607; 2025 WL 3275607 · 2025 WL 3275607
Opinion text not independently reviewed.
Includes texts under the do-not-call provisions. Subsequent appellate posture has not been independently resolved.
2025 U.S. Dist. LEXIS 230981 · LEXIS 230981
Opinion text not independently reviewed.
Includes texts within §227(c).
2:25-cv-03232, ECF 21; 2025 WL 2976546 · *3 (Westlaw)
Opinion text not independently reviewed.
Includes texts under §227(c), but dismisses with leave to amend sender-attribution allegations. A reviewed January 20, 2026 order denies renewed dismissal.
5:25-cv-03996-BLF, ECF 28; 2025 WL 2856295 · pp. 3–6
Opinion text reviewed — automated editorial review
Treats texts as covered by the TCPA's do-not-call protections.
1:25-cv-00538-RP; 2025 U.S. Dist. LEXIS 167479 · *9–15 (LEXIS)
Opinion text not independently reviewed.
Rejects the argument that §227(c)(5) excludes texts; denies dismissal. Later March 24, 2026 summary-judgment order located but not inspected.
6:25-cv-00376-MC, ECF 20; 2025 WL 2029274 · pp. 6–9
Opinion text reviewed — automated editorial review
Follows Steidinger's interpretation that texts are outside §227(c)(5)'s private right of action; grants dismissal without prejudice. A district decision outside the Seventh Circuit, not an Eighth Circuit holding.
6:26-cv-03157-MBB, ECF 28 · text/call analysis and disposition
Opinion text reviewed — automated editorial review
Holds texts are not telephone calls for §227(c)(5)'s private action; affirms dismissal. Applies within the Seventh Circuit, including Illinois, Indiana and Wisconsin. Rehearing/mandate not independently checked.
25-2398; 182 F.4th 532 · pp. 2–13
Opinion text reviewed — automated editorial review
Excludes texts from the §227(c)(5) private action, including the asserted DNC/identification theories, and dismisses with prejudice.
8:25-cv-01657, ECF 52 · pp. 5–13
Opinion text reviewed — automated editorial review
Excludes texts under §227(c)(5), with leave to amend. Later Seventh Circuit Steidinger is consistent on this issue.
1:25-cv-01385-TWP-TAB, ECF 59 · pp. 3–10
Opinion text reviewed — automated editorial review
Excludes texts under §227(c)(5). Separate lawsuit from Shein, decided by the same judge on the same day; not a separate circuit precedent.
1:25-cv-01145-TWP-MKK, ECF 61 · pp. 3–10
Opinion text reviewed — automated editorial review
Reads telephone call in §227(c)(5) as excluding texts and grants dismissal.
1:25-cv-01282-PAG, ECF 29 · pp. 3–8
Opinion text reviewed — automated editorial review
Excludes texts from §227(c)(5) and grants dismissal, while separately finding residential-use allegations sufficient.
1:25-cv-02811-TWT, ECF 31 · pp. 8–14
Opinion text reviewed — automated editorial review
Excludes texts under §227(c)(5); grants dismissal with leave to amend. Mirror URL differs from the docket printed in the opinion.
8:25-cv-00847-SDM-CPT (PDF caption), ECF 27 · pp. 2–4
Opinion text reviewed — automated editorial review
Excludes texts from §227(c)(5) and grants dismissal, without deciding residential-cell coverage. Public appellate docket records voluntary dismissal of appeal 25-13358 on October 14, 2025.
4:24-cv-00477-AW-MAF; 797 F. Supp. 3d 1270 · §II and disposition
Opinion text reviewed — automated editorial review
States texts count as calls, but grants defendant summary judgment because plaintiff failed to produce registration evidence. Favorable statement, not a plaintiff victory.
2:24-cv-06870-JMY, ECF 41; 2026 WL 2244025 · §IV, pp. 4–7
Opinion text reviewed — automated editorial review
Applies do-not-call protections to texts. The litigation also addresses ATDS pleading and consent; not presented as an independently verified contested text/call holding.
4:25-cv-01623; 2026 WL 2224639 · *3 (Westlaw)
Opinion text not independently reviewed.
A footnote quotes Campbell-Ewald's statement that texts qualify as calls. A quoted premise is not necessarily a contested §227(c)(5) holding.
25-15473; 2026 WL 993895 · *1 n.3 (Westlaw)
Opinion text not independently reviewed.
A footnote includes texts within telephone calls under §227(c). Separate from independently inspected, contested scope holdings.
2:25-cv-03531; 2026 WL 916582 · *1 n.1 (Westlaw)
Opinion text not independently reviewed.
States that a text counts as a call under §227(c). The full opinion's treatment of this issue has not been independently inspected.
2025 WL 3764039 · *11 (Westlaw)
Opinion text not independently reviewed.
Allows a text-based DNC claim after deciding residential cell-phone coverage. The text/call distinction was not separately analyzed as a contested issue.
804 F. Supp. 3d 1141; 6:25-cv-00144-AA, ECF 21 · pp. 15–16
Opinion text reviewed — automated editorial review
Includes texts under §227(c). Identified as a magistrate recommendation; adoption not independently checked.
3:25-cv-00231-LS-MAT; 2026 WL 1741206 · *8 (Westlaw)
Opinion text not independently reviewed.
Includes texts. Public docket identifies findings and recommendation, followed by objections; adoption not independently checked.
6:25-cv-02036, ECF 29; 2026 WL 1508003 · *5 (Westlaw)
Opinion text not independently reviewed.
Magistrate recommendation includes texts under §227(c)(5) in a default-judgment analysis. Adoption not independently checked; not counted as an operative district holding.
3:25-cv-00149-DCG, ECF 26; 2026 WL 319779 · pp. 10–11
Opinion text reviewed — automated editorial review
Includes texts under §227(c). Magistrate/district disposition and adoption require confirmation; kept outside operative-holding totals.
3:24-cv-00363-LS-MAT; 2026 WL 1623421 · *8 (Westlaw)
Opinion text not independently reviewed.
Interprets §227(c)(5) to include texts. Later Seventh Circuit Steidinger adopts the opposite interpretation.
1:25-cv-11312; 2026 WL 851279 · 2026 WL 851279
Opinion text not independently reviewed.
Includes texts under §227(c). Later Seventh Circuit Steidinger adopts the opposite interpretation; historical favorable reasoning only.
1:25-cv-06628; 2026 U.S. Dist. LEXIS 23208 · LEXIS 23208
Opinion text not independently reviewed.
Included texts under §227(c)(5). Later Seventh Circuit Steidinger adopts the opposite interpretation; this is historical favorable reasoning, not a current alternative to circuit precedent.
1:25-cv-08012, ECF 32; 2025 WL 3140725 · pp. 2–5
Opinion text reviewed — automated editorial review
Treats text/video messages as calls under §227(b), but affirms dismissal on the voice theory. Does not decide a §227(c)(5) claim.
23-3826; 164 F.4th 1119 · pp. 9–14
Opinion text reviewed — automated editorial review
Does not decide whether texts qualify under §227(c)(5); the numerical threshold disposes of the claim. Not an exclusion holding.
2:26-cv-01150, ECF 53 · discussion of §227(c)(5)
Opinion text reviewed — automated editorial review
Stays discovery and reserves a later merits decision. Not a holding that texts fall outside the statute.
25-61164-CIV-SINGHAL, ECF 31 · pp. 1–4
Opinion text reviewed — automated editorial review
The collection organizes federal case law by jurisdiction, statutory provision and the question decided. Each record identifies its citation, opinion availability and editorial review status. Opinion text has not been independently reviewed for every record. Review of an opinion does not establish its complete subsequent history.
Inclusion and exclusion concern the meaning of the statute—not whether the plaintiff won, whether consent existed or whether money was awarded. Supporting statements, recommendations, historical contrary decisions and §227(b) cases appear in separate groups. A case is not counted twice just because it has multiple orders.
State filters locate federal trial-court decisions and include regional appellate authority. They do not survey state statutes or state-court decisions, determine proper venue, or make one district decision binding throughout a state. The map does not use a favorable/unfavorable heat scale.
Research was performed September 17–18, 2026 using open court documents and public opinion mirrors. The corpus is incomplete; no commercial citator or complete live PACER docket sweep was performed. A reviewed opinion may have subsequent proceedings not captured here. Absence of a record is not absence of authority. Reported decisions still awaiting original-source inspection are not described as independently verified.
Download the JSON dataset. Records include classifications, citations, pinpoint references and, where an original opinion was downloaded, its source URL, retrieval timestamp and SHA-256. Filter by circuit or by state plus regional appellate records, then group by classification. The displayed record totals include contextual records; they are not “for” or “against” totals.
September 18, 2026: introduced the collection, separating §227(b), §227(c)(5) decisions, recommendations, supporting discussions and historical Seventh Circuit decisions. Corrected source-supported docket discrepancies during ingestion. Individual source retrieval dates are preserved; launch date does not certify fresh docket review.
Sources and corrections policy · Understand the messages you received · Unwanted-calls resources
Map geometry: 2017 U.S. Census Bureau boundaries, redistributed by us-atlas. ISC license. Simplified geography is for navigation, not jurisdictional boundary disputes.