Seventh Circuit Bars Private TCPA Text Claims Under §227(c)(5)
In-house counsel overseeing marketing, compliance, and TCPA litigation risk for organizations that send text messages must account for the Seventh Circuit’s ruling, which bars a common private TCPA claim for unwanted texts in that circuit and reduces class action exposure.
On July 14, 2026, the Seventh Circuit held in Steidinger v. Blackstone Medical Services that the TCPA’s private right of action under 47 U.S.C. § 227(c)(5), which authorizes suits for unwanted telephone calls, does not extend to text messages. The ruling is binding only in the Seventh Circuit, and does not impact TCPA claims brought under § 227(b) for texts sent via an automatic telephone dialing system without consent, nor does it preempt state “mini-TCPA” laws that explicitly include text messages in their prohibitions. Organizations operating in the Seventh Circuit facing TCPA text claims under § 227(c)(5) can cite this decision to seek dismissal, while those outside the circuit may use it as persuasive authority to argue against similar claims.