Fifth Circuit Confirms: Oral Consent Is Enough Under the TCPA

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Why it matters

The U.S. Court of Appeals for the Fifth Circuit affirmed a district court's summary judgment in Bradford v. Sovereign Pest Control of Texas, Inc., ruling that the Telephone Consumer Protection Act (TCPA) requires only prior express consent—encompassing both oral and written forms—for prerecorded calls to wireless numbers, rejecting the FCC's regulation mandating prior express written consent for telemarketing calls.[1][2][3][4][5][6][8]

Key parties include plaintiff Michael Bradford, who sued after receiving prerecorded renewal calls; defendant Sovereign Pest Control of Texas, Inc., which obtained Bradford's cell number during a service agreement without call limitations or objections from him; the FCC, whose 47 C.F.R. § 64.1200(a)(2) was deemed to exceed statutory text; and the Fifth Circuit, applying plain-meaning interpretation post-Loper Bright Enterprises v. Raimondo (overturning Chevron deference) and McLaughlin.[1][2][3][4][5][6][7][8] The TCPA (1991) prohibits such calls absent "prior express consent of the called party," defined at enactment as consent "directly given, either viva voce or in writing."[1][3][5]

This stems from Bradford providing his number for contact in a business relationship, upheld as sufficient consent; the ruling, issued February 25 or 26, 2026, directly flows from Loper Bright (2024), enabling courts to independently interpret TCPA text without FCC deference.[1][2][4][6][9][10] Prior FCC rules had imposed stricter written consent for telemarketing, creating liability risks.

Newsworthy now (published February 27, 2026) as a major shift shielding businesses—especially those relying on oral/implied consent via customer relationships—from TCPA class actions in Texas, Louisiana, and Mississippi, potentially upending litigation while complicating proof of non-written consent; state laws may differ.[2][3][4][7] It signals broader post-Loper Bright challenges to agency TCPA rules.[1][4][10]

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