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ARTICLE · 20 JULY 2026

Seventh Circuit Holds That The TCPA’s Do-Not-Call Provision Does Not Cover Text Message

Duane Morris LLP
Duane Morris LLP
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The Seventh Circuit Court of Appeals has issued a landmark ruling that text messages do not constitute "telephone calls" under Section 227(c)(5) of the Telephone Consumer Protection Act, significantly limiting private rights of action for unwanted text message claims. This decision marks the first federal appellate court to squarely address this issue and creates a circuit split with the Ninth Circuit's contrary interpretation. Companies operating in Illinois, Indiana, and Wisconsin now face substantially r

United StatesLitigation, Mediation & Arbitration
Gerald Maatman, Jr.
Gerald Maatman, Jr.
Jennifer A. Riley
Jennifer A. Riley
Ryan Garippo
Ryan Garippo
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Duane Morris Takeaways: On July 14, 2026, in Steidinger, et al. v. Blackstone Medical Services, No. 25-2398, 2026 WL 2028517 (7th Cir. July 14, 2026), Judge Thomas Kirsch, writing for the U.S. Court of Appeals for the Seventh Circuit, affirmed the dismissal of a putative class action complaint and held that 47 U.S.C. § 227(c)(5) of the Telephone Consumer Protection Act (“TCPA”) does not create a private right of action for the receipt of unwanted text messages. 

The decision is significant because it represents the first federal appellate decision squarely holding that text messages are not “telephone calls” within the meaning of Section 227(c)(5) and significantly reduces potential TCPA-related liability for companies operating in the Seventh Circuit.

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