Status of Texts as Calls - October 2026
Is a text message a “telephone call” under the Do Not Call rules of the TCPA, 47 U.S.C. § 227(c)(5)? This map from Perrong Law LLC tracks how federal courts have answered. Green means the court found texts are calls. Red means it found they are not. Grey means we have not found a ruling there yet. Hover over a district to see the cases, or click it to change the color.
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Submit an inquiryThis list may be incomplete or contain errors. New decisions come out all the time, and we may have missed a case or put one in the wrong column. Please read the opinions and check the current law before relying on anything here.
Rulings shown on the map
Know of a case we missed?Help us keep this map accurate. If you know of a decision on whether texts are calls under § 227(c)(5), win or lose, please send it to us at perronglaw.com. We welcome corrections too.
Submit a caseAll districts
District colors reflect decisions on § 227(c)(5) as of October 7, 2026. A few entries are magistrate judges’ recommendations, or decisions that applied § 227(c) to texts without deciding the question. Those are marked in the case list. Steidinger binds every district in the Seventh Circuit, so the whole circuit is red. The whole Ninth Circuit is green because its district courts follow Howard v. Republican National Committee, 164 F.4th 1119 (9th Cir. 2026), and Satterfield. Howard itself was decided under § 227(b), not § 227(c)(5). The Court of Appeals for the Federal Circuit hears certain kinds of cases from across the country, so it appears as a button instead of a place on the map. Puerto Rico and the territorial courts (Guam, the Northern Mariana Islands and the Virgin Islands) are listed under their circuits. District lines follow 28 U.S.C. §§ 81 to 131.