Supreme Court Reshapes TCPA Interpretation in Landmark McLaughlin Ruling

In a ruling that significantly alters how courts interpret the Telephone Consumer Protection Act (TCPA), the U.S. Supreme Court decided on June 20, 2025, that federal district courts are no longer bound to follow FCC interpretations when adjudicating TCPA cases. The decision came in McLaughlin Chiropractic Associates, Inc. v. McKesson Corp., and is expected to reshape the legal landscape for businesses engaged in outbound calling and text campaigns.

The Court held that district courts have the authority to interpret the TCPA independently, even if the FCC has issued prior guidance. This means rulings on key terms—like what constitutes an “autodialer” or whether a mobile number is considered “residential”—may now vary across jurisdictions.

Key implications for contact centers and marketers

Increased legal uncertainty 

The loss of FCC deference could lead to conflicting rulings on core TCPA definitions, depending on the court.

Autodialer risk divergence

Outbound systems may be judged differently across federal districts, prompting some businesses to adopt more conservative dialing technologies.

Do Not Call rule impact

Courts may begin assessing whether a mobile number is used personally or for business, complicating DNC compliance strategies.

Consent scrutiny

The longstanding presumption that providing a phone number implies consent is now in question, elevating the need for clear, documented permissions.

Consent still matters post McLaughlin

Despite the shift away from FCC authority, the Court did not alter the TCPA’s explicit ban on calls made with an “artificial or prerecorded voice” without prior express consent.

As regulatory interpretations diverge and plaintiff activity increases, experts recommend that businesses revisit their outbound compliance policies, re-validate consent collection practices, and work closely with legal counsel and compliant technology providers.

Convoso customers have access to manual dialing tools like CallCatalyst™, built-in compliance tools and next generation caller ID reputation management to support compliance-minded businesses looking for flexible outreach while managing evolving risk.

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