What did the court decide in Callier v. The Finish Line?

N.D. Tex. ruled against the defendant on critical TCPA issues, including whether text messages count as calls under the statute, in a case brought by a pro se litigant.

Does this ruling affect SMS marketing compliance?

Yes. The case addressed whether SMS messages are treated as calls under the TCPA, which is directly relevant to do-not-call and autodialer rules for text campaigns.

When was the ruling issued?

The decision, 2026 WL 2654093, was issued in N.D. Tex.

Friday, September 11, 2026

Pro Se Litigant Beats TCPA Defendant on SMS DNC and ATDS in N.D. Tex.

A pro se litigant won on core TCPA issues against a defendant in Callier v. The Finish Line, Inc., including the question of whether text messages count as calls. The ruling came out of N.D. Tex.

1Lookup Signal Report

68.8% of 2,104 phone checks on 1Lookup came back mobile

Across 2,104 checks run on the 1Lookup platform on 2026-09-11, 68.8% came back mobile, down 7.0 points from the trailing seven-day average of 75.8%. Email deliverability also ran below its recent average, with 73.4% of 2,007 checks coming back deliverable versus a 77.8% baseline, down 4.4 points. Phone number status held steadier, with 88.4% of 2,104 checks active.

Phone line types

2,104 checks

mobile68.8%
other line types31.2%

Phone number status

2,104 checks

active88.4%
other line types11.6%

Email deliverability

2,007 checks

deliverable73.4%
other line types26.6%

Measured across every completed lookup on the 1Lookup platform for this UTC day. Aggregate only: no customer, organisation or lookup input is published, and any bucket too thin to be anonymous is withheld.

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Pro se litigant defeats TCPA defendant on SMS do-not-call and ATDS issues in N.D. Tex. ruling
In Callier v. The Finish Line, Inc., 2026 WL 2654093 (N.D. Tex. Aug. 19, 2026), a pro se litigant won on critical TCPA issues against the defendant, including whether text messages qualify as calls under the statute. The report describes the loss as complete and crushing for the defendant on these points.
Why it matters: Any business texting prospects needs to treat SMS as a covered call type under the TCPA. A ruling like this raises the stakes for do-not-call and autodialer compliance on text campaigns, not just voice calls.
- TCPAWorld

Questions people asked today

What did the court decide in Callier v. The Finish Line?: N.D. Tex. ruled against the defendant on critical TCPA issues, including whether text messages count as calls under the statute, in a case brought by a pro se litigant.
Does this ruling affect SMS marketing compliance?: Yes. The case addressed whether SMS messages are treated as calls under the TCPA, which is directly relevant to do-not-call and autodialer rules for text campaigns.
When was the ruling issued?: The decision, 2026 WL 2654093, was issued in N.D. Tex.

Check your own numbers against this

Why are my calls showing as spam likely? · What share of phone numbers are VOIP? · How many numbers are invalid or disconnected?

Pro Se Litigant Beats TCPA Defendant on SMS DNC and ATDS in N.D. Tex.

Pro se litigant defeats TCPA defendant on SMS do-not-call and ATDS issues in N.D. Tex. ruling

Questions people asked today

Check your own numbers against this