The Seventh Circuit Court of Appeals has ruled that text messages are not considered ‘calls’ under the Telephone Consumer Protection Act (TCPA). This decision, in Steidinger v. Blackstone Medical Services, could have far-reaching implications for how unwanted marketing texts are regulated. The case, No. 25-2398 (7th Cir. July 14, 2026), shows the evolving challenges in applying decades-old legislation to modern communication technologies.
The case began when plaintiffs received marketing texts from Blackstone Medical Services, despite requests to stop and their inclusion on the Do-Not-Call Registry. They filed a class action lawsuit under the TCPA, but the district court dismissed the claims, agreeing with the defendant that the relevant TCPA provision, 47 U.S.C. § 227(c)(5), only covers phone calls. The plaintiffs appealed, arguing that the statute’s language should be interpreted broadly to include text messages, but the Seventh Circuit upheld the dismissal, emphasizing the statute’s specific reference to “calls.”
A Conflict Among Courts
The Seventh Circuit’s decision creates a split with other circuit courts that have interpreted the TCPA differently. For instance, some courts have held that text messages fall under the TCPA’s purview, particularly when they are automated or unsolicited. This inconsistency may lead to the U.S. Supreme Court ultimately resolving the issue, as lower courts continue to grapple with the statute’s application to emerging communication methods.
The TCPA and Its Limits
The TCPA, enacted in 1991, was designed to protect consumers from unsolicited telemarketing calls. Its application to text messages, a technology that emerged later, has been a subject of debate. The statute’s original focus on “calls” reflects the technology sector of the early 1990s, when text messaging did not exist as a widespread marketing tool. As a result, courts have been divided on whether the TCPA’s protections extend to this modern form of communication.
What’s Next for TCPA Litigation?
The ruling in Steidinger v. Blackstone is likely to spur further litigation as consumers and businesses work through the TCPA’s boundaries. With circuit courts divided, the Supreme Court’s intervention seems increasingly probable. Until then, legal experts anticipate a surge in cases testing the limits of the TCPA’s applicability to text messages, particularly in jurisdictions where the law remains unsettled.