Michigan Ruling Opens Door to Lawsuits Over Caller ID Violations
In a case that could have nationwide implications, the Eastern District of Michigan has ruled that individuals can sue for caller ID violations.
In Dobronski v. Selectquote Ins. Servs., 2025 U.S. Dist. LEXIS 54413 (Mar. 25, 2025), plaintiff Dobronski, representing himself, argued that under the Telephone Consumer Protection Act (TCPA), individuals have the right to take legal action when the caller ID regulations—outlined in 47 C.F.R. § 64.1601(e)—are violated.
Initially, the court sided with the defendants, ruling that these regulations fell under 47 U.S.C. § 227(e), which has no private right of action. But Dobronski pushed back, filing a motion for reconsideration and arguing that the court had misinterpreted the TCPA and its related rules.
Upon review, the court realized that the caller ID regulations predated the addition of § 227(e) to the TCPA, meaning it could not fall under that section.
The court then reconsidered whether the caller ID regulations actually fall under § 227(c) or § 227(d). Complicated, but a key distinction because § 227(c) allows for a private right of action, while § 227(d) does not.
After re-examining the issue, the court flipped its stance, deciding the caller ID regulations do, in fact, fall under § 227(c)—meaning private individuals can sue for caller ID violations.
While most previous rulings have gone the other way, the court found Dobronski’s arguments (and the minority view) more persuasive. As a result, he’ll be able to move forward with his case against the defendants.
This ruling could be an outlier, but it’s likely to spark more lawsuits, especially in the Sixth Circuit. To stay compliant, make sure you’re following the caller ID requirements, which include:
Displaying either the CPN (Calling Party Number) or ANI (Automatic Number Identification); and
Showing the telemarketer’s name, if available from their carrier.
You can substitute the seller’s name (the company on whose behalf the call is made) instead of the telemarketer’s name. However, the phone number displayed must be the seller’s customer service number, and it must allow people to make a “do-not-call” request during business hours.
With this new ruling, compliance just became even more important—so double-check your caller ID practices now.