Third Circuit Reaffirms Narrow Interpretation of TCPA, Holds State Legislators’ Constituent Communications Outside Statute's Reach

The Third Circuit’s recent decision in Perrong v. Bradford, 2025 WL 2825982 (3d Cir. 2025), serves as an important reminder that the TCPA does not apply to all automated telephone solicitations. In a case of first impression, the Court held that telephone solicitations made by state legislators when performing legitimate legislative functions for the public benefit fall outside the statute's scope — underscoring that courts continue to interpret the TCPA narrowly and recognize meaningful limits on its application.