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Sixth Circuit Holds Receipt of One Ringless Voicemail Causes Article III Harm Under the TCPA

On June 1, the Sixth Circuit Court of Appeals issued a ruling in Dickson v. Direct Energy, LP, holding that the plaintiff’s claims that he received a single ringless voicemail (RVM) for commercial purposes satisfy the demands...more

Case Update: Tenth Circuit Affirms District Court Decision Requiring Substantial Changes to Health Plan Denial Letters

As discussed here, D.K. et al. v. United Behavioral Health et al. is a case that has been carefully watched in the health benefits space for its potential to change what health plan administrators must include in adverse...more

Sixth Circuit Affirms Dismissal of FDCPA Suit Arising From Pandemic-Time In Person Service of Process

The Sixth Circuit recently affirmed a district court’s dismissal of a Fair Debt Collection Practices Act (FDCPA) and Michigan Regulation of Collection Practices Act (RCPA) suit, holding that the plaintiff lacked standing. The...more

Florida State Court Holds Mere Statutory Violation Not Enough to Confer Standing Under TCPA

On May 10, Florida’s Third District Court of Appeal issued an opinion in Pet Supermarket, Inc. v. Eldridge, holding that the plaintiff and putative class representative lacked standing to pursue his class action lawsuit under...more

Florida Legislature Narrows Litigation-Spawning Telephone Solicitation Act

On May 2, the Florida legislature passed amendments to the Florida Telephone Solicitation Act (FTSA) that would drastically narrow its scope and presumably cut down on the number of class actions filed pursuant to it. The...more

Washington Robocall Bill Signed Into Law

As discussed here, on April 7, the Washington State legislature passed HB 1051, also known as the Robocall Scam Protection Act, expanding the scope of existing provisions of Washington’s consumer protection laws regulating...more

The Ninth Circuit Reinforces Narrow Interpretation of ATDS under Borden Holding System Must Generate Random or Sequential...

On April 13, the Ninth Circuit issued an opinion affirming a district court’s summary judgment order on the grounds that under Borden v. eFinancial, LLC, discussed here, to qualify as an automatic telephone dialing system...more

Courts Continue to Scrutinize ERISA Health Plan Benefit Denial Letters

As discussed here, administrators’ health plan benefit denial letters have recently been under scrutiny by the courts. For example, in D.K. et al. v. United Behavioral Health et al., the Tenth Circuit is reviewing a district...more

New Washington Bill Expands Protections Against Robocalls and Commercial Telephone Solicitations

On April 7, the Washington State legislature passed HB 1051, also known as the Robocall Scam Protection Act, which expands the scope of existing provisions of Washington’s consumer protection laws regulating robocalls and...more

No FCRA Violations Found Where Defendants Promptly Corrected Inaccurate Data and Updated Plaintiffs’ Consumer Report

In a recent decision, the U.S. District Court for the Eastern District of Pennsylvania granted summary judgment in a Fair Credit Reporting Act (FCRA) case where a bank promptly corrected inaccurate mortgage payment...more

Treble Trouble in Paradise: Court Refuses to Treble Jury’s $8,500 TCPA Award to Plaintiff

On April 4, the U.S. District Court for the Northern District of Texas declined to increase or treble the plaintiff’s $8,500 jury trial damages awarded under the Telephone Consumer Protection Act (TCPA) after failing to find...more

New York Federal Court Partially Denies MSJ in TCPA Case Finding Possession of Cell Number Does Not Prove Consent

A federal district court in the Western District of New York recently denied in part a motion for summary judgment in a case alleging violations of the Telephone Consumer Protection Act (TCPA) based on collection calls and...more

Federal Magistrate Judge Orders CFPB to Produce Employees for Depositions in Citizens Bank Lawsuit

A federal magistrate judge in Rhode Island has ruled that the Consumer Financial Protection Bureau (CFPB or Bureau) must produce three employees for depositions, denying the agency’s motion for a protective order....more

FCC Cracks Down on Texting Scams and Robocalls

On March 16, the Federal Communications Commission (FCC) adopted its first set of regulations targeting what is perceived as the increasing problem of scam text messages sent to consumers. The first rule requires mobile...more

The State of Wilderness Therapy Program Exclusions in ERISA Health Plans

In recent years, several lawsuits have challenged wilderness therapy program exclusions in health plans. Not only do members typically assert a claim for benefits, alleging a denial of wilderness therapy benefits was improper...more

Pennsylvania Federal Court Certifies TCPA Class Finding Common Question in Determining Existing Business Relationship

In a class action lawsuit against Pisa Group, Inc. for alleged violations of the Telephone Consumer Protection Act (TCPA), the plaintiff moved to certify a class of all persons in the United States who received more than one...more

Take Two: En Banc Eleventh Circuit to Address Whether a Single Text Message Can Confer Standing Under TCPA

As discussed here, on July 27, 2022, the Eleventh Circuit Court of Appeals sua sponte vacated the district court’s approval of a $35 million class-action settlement in Drazen and Godaddy.com, LLC (Godaddy) v. Pinto. Although...more

New Wyoming Bill Requires Licensure for Debt-Buyers

On February 27, Wyoming Governor Mark Gordon signed into law House Bill 284, which requires debt buyers be licensed as “collection agencies” starting July 1, 2023....more

Tenth Circuit Holds Arbitration Provision in ERISA Plan Document Unenforceable

Recently, the Tenth Circuit Court of Appeals held an arbitration provision impermissibly blocked rights afforded to a retirement plan participant under the Employee Retirement Income Security Act (ERISA) and was therefore...more

Consumer Advocates Respond to DentalPlans’s FCC Petition Regarding Membership Renewal Calls

As the Federal Communications Commission (FCC) considers whether DentalPlans.com’s (DentalPlans) plan renewal calls constitute telemarketing under the Telephone Consumer Protection Act (TCPA), multiple interested parties,...more

California Court of Appeals Suggests Electronic Signatures Require Additional Proof for Authentication

On January 19, a California Court of Appeals issued a decision calling into question the evidentiary value of electronic signatures. Dicta in the opinion directly contradicts a previous ruling in Gamboa v. Northeast Community...more

CMS Publishes Final Rule Increasing Government Authority to Recover Overpayments from Medicare Advantage Plans

On February 1, the Centers for Medicare & Medicaid Services (CMS) published a final rule strengthening their authority to recover alleged overpayments made to Medicare Advantage plans. The rule formalizes the Medicare...more

Amended TCPA Exemptions Rule Published

As previously reported here, the Federal Communications Commission (FCC) issued a proposed rule specifying that to be exempt from the Telephone Consumer Protection Act’s (TCPA) consent requirements callers would be limited to...more

2/3/2023  /  FCC , Robocalling , TCPA , Telecommunications

FCC Issues Mixed-Bag Amended TCPA Exemptions Order

As previously reported here, the Federal Communications Commission (FCC) issued a proposed rule in December 2020 that would place new call-frequency limitations and opt-out requirements on certain prerecorded...more

Tenth Circuit to Decide Case that Could Substantially Change Health Plan Denial Letters

In October 2022, the Tenth Circuit heard oral argument in D.K. et al. v. United Behavioral Health et al., a case that could significantly impact what health plans must include in any notification to claimants of an adverse...more

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