Analyzing the Written Consent Ruling

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Welcome to Compliance Pointers, where we take
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an in -depth look into the latest news, trends,
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and challenges surrounding information security,
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privacy, and marketing compliance. Let's dive
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in with your host, Jordan Eisner. All right.
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Hello, and welcome to another episode of Compliance
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Pointers and another guest appearance by our
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very own Tony Jarnigan. Hey, Tony. Good to have
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you. Thank you very much, Jordan. It's been a
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while. Yeah. And this podcast will be released
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in the future, but as of this very moment, March
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Madness has continued today. It's Friday, and
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Santa Clara and Kentucky are in a battle. It
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looks like Kentucky is going to pull out, but
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we will do our best to stay focused here on this
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podcast. I don't have any scores or anything
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up. We're here to learn about the... the details
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on the bradford verse sovereign pest control
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of texas case which apparently is creating a
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little bit of buzz in the uh the telemarketing
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compliance space so um for those of you who don't
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know or maybe need to refresh compliance pointers
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is the podcast of compliance point that's the
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company that tony and i both work for i am the
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vp of growth at compliance point tony are you
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Consultant? Is that the official title? Consultant.
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Consultant. There you go. I've been looking for
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ways to see if we can embellish that somewhat,
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but as of now, it's still consultant. Consultant
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extraordinaire. Thank you. There you go. CE for
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short. As mentioned, we're going to get into
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the Bradford v. Sovereign Pest Control of Texas
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case today with Tony here. So let's dive right
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in. Give us the details on that case, Tony. Yeah,
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well, it's an interesting case to be sure. But,
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you know, just to give you a little bit of background,
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I'm assuming four or five years ago, the plaintiff
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entered into a service plan agreement with Sovereign
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Pest Control and provided his cell phone number
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so that the company could continue to contact
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him. And then each year for about four years,
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the Sovereign Pest Control used prerecorded messages
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to remind him to schedule his annual renewal
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inspections. And then the guy actually ends up
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being a serial litigant. And so four years into
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this, he, I guess, learns about this and says,
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you know what? Four years ago, they never got
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my express written consent. which is what is
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needed to deliver prerecorded messages to my
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cell phone. And so he brought a suit and the
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fifth, the the trial court held that these were
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only informational texts. They weren't solicitous.
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And so this ends up being, you know, sort of
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an a result of a ruling from the FCC in 2012,
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I believe, where they said that you have to have
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express written consent to deliver a pre -recorded
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message or artificial voice, or if you're using
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an ATDS to a cell phone for telemarketing calls.
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But you only need express consent for informational
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calls. And the difference there is that if I'm...
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I can give you my phone number during the normal
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course of business and with no consent language
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or checking a box or signing anything. And that's
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considered express consent. However, express
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written consent means that I have to sign or
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digitally sign or check a box or that sort of
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thing. So this is, you know, Right. Right. Exactly.
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Certain disclosures. So he says, you know, they
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didn't have my express written consent. So I'm
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going to sue. And like I said, the trial court
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said, well, actually, we wouldn't consider these
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to be solicitous messages. They're only informational.
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So he appealed. And then on appeal, the Fifth
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Circuit Court of Appeals held that the TCP only
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requires prior express consent, not prior express
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written consent, even for telemarketing. pre
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-recorded calls to wireless numbers. And so this
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ends up being another challenge to the FCC ruling,
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right, from 2012, or another challenge to FCC's
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positions and interpretations, and said that,
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you know, we don't, you know, this is all, I
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don't want to get too far ahead of ourselves
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here, but this is all a result of, you know,
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those two important cases from 2024 and 2025,
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you know, the Loper -Bright decision. in 2024
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and mclaughlin chiropractic associates decision
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in 2025 uh that held that uh you know trial courts
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or you know federal trial courts are not bound
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to be to in follow fcc interpretations um so
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that's that's exactly what's happened here we
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sort of anticipated it there's a lot of professionals
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in our space that have anticipated this i know
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you had alex presovic on last year you know,
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and went through a litany of things and said,
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well, what do we think will be challenged? And
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one was that texts aren't calls, and we know
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that that's being challenged. And now the challenge
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to this, the FCC ruling from 2012 that says that,
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you know, certain calls for certain purposes
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has to be in writing, because the TCPA does not
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say that at all. So that's exactly the, I mean,
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that's the groundwork for this decision. Yeah.
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Well, you covered a lot of territory there, I
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think. We did. No, it's good. It's all connected.
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Yeah, yeah. Well, the background, the details
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of the case, but then also I think why it's creating
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buzz, because, and we're lumped right in there,
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had always understood that if it's a solicitation,
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right, a telemarketing call, that it would require
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express written consent. Right. And the Fifth
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Circuit Court of Appeals says it doesn't make
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any difference in the first place whether they're
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informational or solicitous because the TCPA
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doesn't require it for any type of call. So what
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do you do with that? Well, what you do with it
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is you have to think about, well, what court
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is this, right? It is a federal court. It's the
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Fifth Circuit Court of Appeals. And the Fifth
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Circuit Court of Appeals covers Texas, Louisiana,
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and Mississippi. So we've got states throughout
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the country that are part of different circuit
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courts of appeal. There's 13 circuit courts of
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appeal across the country. And this is the Fifth
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Circuit Court of Appeals. And so this decision
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is only binding on trial -level courts in those
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three states. So, you know, immediately, you
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know, we started hearing businesses saying, well,
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gee, if I only operate in those three states,
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you know, I've got a small business. I only operate
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in Texas or or Louisiana or Mississippi. Then,
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you know, I don't need I don't need express written
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consent to send prerecorded messages. Just need
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a phone number. Right. Right. But you've got
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to be careful. Right. Because, you know. There
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are, as you pointed out earlier, right, some
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of these rules and laws could come from the state
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level, right? So we know that Texas, for example,
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as a result of SB 140 last year that went into
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effect on September 1, right, they have consent
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requirements. They don't necessarily define consent,
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but because of the risk that's associated there,
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you know, the private right of action, everybody's
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saying, you know, apply the highest standard
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possible to your consent in Texas. So I wouldn't
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necessarily advise that, you know, you're going
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to get a free ride here now. There's other, you
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know, we could very well see a decision from
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a district court of appeal and another district
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court of appeal to rule differently. And then,
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you know, then when you've got that happen, then
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you've got a, you know, you've got what's considered
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a circuit court split. where one is ruling one
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way and one is ruling another. And then, you
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know, usually the most logical conclusion there
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is for it to be, you know, one of those to be
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elevated to the Supreme Court and have the Supreme
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Court decide. What would really be great is if
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the Congress could finally amend, you know, the
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TCPA to give some, shed some light on some of
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this stuff, right? I mean, I've often said, I
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think I've even said on your podcast that, you
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know, People think, well, yeah, the FCC, they're
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overreaching. The administrative state in our
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country is now the fourth branch of government,
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and they're overreaching, and they're making
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law instead of passing rules to implement laws.
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But they're the ones, the FCC and the FTC in
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our world, they're the ones who are getting these
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complaints, right? so uh they're the ones that
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say well gee now technology is advanced now we've
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got texts you know what do we do with texts and
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they're saying okay well yeah we think that texts
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are calls um what are we doing about robocalls
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you know we're you know my phone's blown up from
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pre -recorded messages from people that i didn't
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even give consent to uh they're saying well okay
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then it needs to be and and consent should be
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in writing right to to and to your point you
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know you have to agree to all those disclosures
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um so you know they're i see it as that they've
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been trying to step in and clear the air on a
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lot of this stuff you know where technology is
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outpacing the laws uh or in this case the tcpa
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because uh uh you know congress hasn't acted
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to amend it you know we saw an attempt what was
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it early 2024 with what was called the do not
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disturb act um you know that would have addressed
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some of this stuff and um but it didn't for whatever
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reason it didn't go anywhere we thought it might
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be uh picked back up in 2025 but so far we haven't
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seen anything in 2025 or 2026. yeah it's got
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to be confusing for for telemarketers right now
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all right when i say telemarketers i mean when
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compliance point says telemarketers we're using
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a lot of times you know federal or state definitions
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of telemarketer which is broad that's why you
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know i think it's not only interesting that the
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trial court said it doesn't matter what the tcpa
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doesn't require express written consent right
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that's surprising itself but also that the initial
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ruling that there were informational calls because
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part of what i have always been told is that
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if it's part of a plan or a campaign right for
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some sort of solicitation even not initially
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but down the line I mean, I could see that argued
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that way, too. It's a reminder about a renewal,
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right, of services where a payment's probably
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going to be exchanged. Right, right. Very interesting.
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So, yeah, it's got to be a confusing time. Absolutely.
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I think to your point that, you know, there's
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another school of thought out there that says
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that, you know, if you're whatever steps you're
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trying to take to consummate a deal or another
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deal or an upgrade or to re -up, right you know
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that that could be solicitous in and of itself
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but you know in this particular case the you
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know the trial court initially said that no we
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think these are informational calls you know
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they they they went by the the the uh the construct
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of the fcc if you will right and said no these
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are informational calls so they don't need a
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written consent the fact that the plaint the
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plaintiff supplied his number during the normal
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course of business is sufficient here and but
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what i find interesting too is is that um you
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know, this Fifth Circuit Court of Appeals, they
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could have just affirmed that, right? They could
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have just said, you know, we think these are
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informational calls as well, and therefore, you
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know, we're going to affirm the lower court decision.
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But they went a step further. They said it doesn't
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make any difference whether they're informational
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or solicitous, because we don't think that the
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TCPA requires express written consent to begin
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with. Very interesting. Yeah. Yeah, because I
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was thinking, too, even when you were talking
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about small businesses only telemarketing in
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Texas, Louisiana or Mississippi, you know, maybe
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they start to take that. But you're right. It
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seems like there's other gotcha ways, right,
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that they could get, you know, find themselves
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in hot water. Because when you were saying that,
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I was also thinking, well, what about I mean,
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Texas is a big state. A lot of residents in Texas,
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a lot of consumers for even a company that does
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market into all states to almost segment residents
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of Texas and say, hey, we only need this sort
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of consent for them, you know, dial away. But
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I think there's just many other, you know, avenues
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probably where they could. find themselves out
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of compliance just because one trial court says
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and i think you summed that up pretty well so
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you know i think to put a bow on it and i know
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i think we're only 15 minutes or so in this but
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you covered it well i think you you gave the
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situation and i would say for for any of our
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listeners that want more you know reach out but
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you gotta continue to to do what you've been
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doing really for the most part it doesn't it
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doesn't necessarily it's a head scratcher maybe
00:14:07.519 --> 00:14:09.799
but not something to take a run with because
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you could find yourselves right on the other
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side of some compliance issues if you do. Yeah,
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I was just going to add, too, that, you know,
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like I said, you know, there were a lot of us
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that said, well, you know, once the Loper -Bright
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decision came out and the McLaughlin decision
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came out and it's like, you know, the trial courts
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don't have to adhere to FCC, it's like, well,
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what changes might we see? right like i said
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you know tax start calls was one of them and
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that it happened within a month i believe um
00:14:39.330 --> 00:14:43.850
and now um you know then another one that was
00:14:43.850 --> 00:14:46.470
on everybody's bingo card if you will was uh
00:14:46.470 --> 00:14:49.389
you know that are we going to find to have a
00:14:49.389 --> 00:14:51.850
court that says that you know that the tcpa doesn't
00:14:51.850 --> 00:14:53.889
require written consent and that and then we've
00:14:53.889 --> 00:14:55.590
got it i don't know where we go from here in
00:14:55.590 --> 00:14:57.149
terms of you know is there going to be another
00:14:58.009 --> 00:15:00.669
topic uh that challenges an fcc interpretation
00:15:00.669 --> 00:15:03.509
um but i know that those were the two that were
00:15:03.509 --> 00:15:05.570
at the top of the list and and they both have
00:15:05.570 --> 00:15:10.950
happened yeah well tony thank you as always very
00:15:10.950 --> 00:15:15.049
uh concise but detailed at the same time so no
00:15:15.049 --> 00:15:17.889
that was good i think that was a good recap for
00:15:17.889 --> 00:15:20.120
our listeners and watchers If you have questions
00:15:20.120 --> 00:15:23.159
on that, if you're considering, you know, what
00:15:23.159 --> 00:15:25.740
sort of adaptations do we make to our campaigns,
00:15:25.899 --> 00:15:28.639
if any, and you want a sounding board for that,
00:15:28.720 --> 00:15:30.779
please don't hesitate to reach out. You can find
00:15:30.779 --> 00:15:33.059
us at compliancepoint .com. You can email us
00:15:33.059 --> 00:15:36.279
directly at connectatcompliancepoint .com. We'd
00:15:36.279 --> 00:15:37.919
be happy to go over your situation with you,
00:15:38.019 --> 00:15:39.840
tell you a little bit more about what we do,
00:15:40.000 --> 00:15:42.340
and see if maybe there's an opportunity to support
00:15:42.340 --> 00:15:45.500
beyond that. And if you like this podcast, please
00:15:45.500 --> 00:15:48.480
continue to listen, subscribe. Tell your friends,
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leave us a review. We'll continue to put out
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content like this and in other areas of regulatory
00:15:55.679 --> 00:15:59.740
compliance and information security. Tony, have
00:15:59.740 --> 00:16:02.899
a great rest of your day and everybody else be
00:16:02.899 --> 00:16:04.779
well. Thank you very much, Jordan.