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Really big win here for companies leveraging SMS to outreach with consumers for multiple purposes– but be careful because this rule will likely evaporate next April
In Stamper v. Manus- Northwestern, 2025 WL 2044093 (N.D. Ill. July 17, 2025) a consumer had opted in to receive two types of messages– “waitlist messages” and “continuing care recall messages.” Her number was also the point of contact for at least two other clients (presumably her relatives).
Stamper replied “STOP” to one of the messages and she received an automated follow-up text informing her that she had successfully unsubscribed from that particular category of communications and instructing her to “please reply STOPALL” “[i]f you would like to stop all communications from Manus Dental.” Compl. 2-4. But she never did.
Still Plaintiff sued arguing that the single “STOP” was sufficient to require the defendant to cease all SMS communication across all purposes. The Court disagreed.
Instead the court determined “Stamper clearly communicated a desire to unsubscribe from the specific type of message that she had just received, on behalf of the client to whom that message had been directed. She did not, however, clearly communicate a desire to unsubscribe to any and all text messages from Manus.”
Nice right?
A very thoughtful ruling and one that conforms with common sense, especially since the defendant offered a “Stop All” option in the confirmation text message.
As nice as this ruling is, don’t get too comfortable with it. The FCC has adopted a contrary ruling–one treating a “stop” as a multi-channel, multi-purpose opt out— and that rule is set to go into effect next April.
While FCC TCPA rulings no longer have the binding effect they once did, you can expect many courts will apply the new cross-channel cross-purpose rule and– when they do– a “stop” will certainly nuke communications of the sort at issue in Stamper.
So watch out!
Take aways here:
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Find Your Next Job !
Really big win here for companies leveraging SMS to outreach with consumers for multiple purposes– but be careful because this rule will likely evaporate next April
In Stamper v. Manus- Northwestern, 2025 WL 2044093 (N.D. Ill. July 17, 2025) a consumer had opted in to receive two types of messages– “waitlist messages” and “continuing care recall messages.” Her number was also the point of contact for at least two other clients (presumably her relatives).
Stamper replied “STOP” to one of the messages and she received an automated follow-up text informing her that she had successfully unsubscribed from that particular category of communications and instructing her to “please reply STOPALL” “[i]f you would like to stop all communications from Manus Dental.” Compl. 2-4. But she never did.
Still Plaintiff sued arguing that the single “STOP” was sufficient to require the defendant to cease all SMS communication across all purposes. The Court disagreed.
Instead the court determined “Stamper clearly communicated a desire to unsubscribe from the specific type of message that she had just received, on behalf of the client to whom that message had been directed. She did not, however, clearly communicate a desire to unsubscribe to any and all text messages from Manus.”
Nice right?
A very thoughtful ruling and one that conforms with common sense, especially since the defendant offered a “Stop All” option in the confirmation text message.
As nice as this ruling is, don’t get too comfortable with it. The FCC has adopted a contrary ruling–one treating a “stop” as a multi-channel, multi-purpose opt out— and that rule is set to go into effect next April.
While FCC TCPA rulings no longer have the binding effect they once did, you can expect many courts will apply the new cross-channel cross-purpose rule and– when they do– a “stop” will certainly nuke communications of the sort at issue in Stamper.
So watch out!
Take aways here:
More Upcoming Events
Â
Sign Up for any (or all) of our 25+ Newsletters
Â
You are responsible for reading, understanding, and agreeing to the National Law Review’s (NLR’s) and the National Law Forum LLC’s  Terms of Use and Privacy Policy before using the National Law Review website. The National Law Review is a free-to-use, no-log-in database of legal and business articles. The content and links on www.NatLawReview.com are intended for general information purposes only. Any legal analysis, legislative updates, or other content and links should not be construed as legal or professional advice or a substitute for such advice. No attorney-client or confidential relationship is formed by the transmission of information between you and the National Law Review website or any of the law firms, attorneys, or other professionals or organizations who include content on the National Law Review website. If you require legal or professional advice, kindly contact an attorney or other suitable professional advisor. Â
Some states have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals. The National Law Review is not a law firm nor is www.NatLawReview.com  intended to be a referral service for attorneys and/or other professionals. The NLR does not wish, nor does it intend, to solicit the business of anyone or to refer anyone to an attorney or other professional.  NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us.Â
Under certain state laws, the following statements may be required on this website and we have included them in order to be in full compliance with these rules. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. Statement in compliance with Texas Rules of Professional Conduct. Unless otherwise noted, attorneys are not certified by the Texas Board of Legal Specialization, nor can NLR attest to the accuracy of any notation of Legal Specialization or other Professional Credentials.
The National Law Review – National Law Forum LLC 2070 Green Bay Rd., Suite 178, Highland Park, IL 60035 Telephone  (708) 357-3317 or toll-free (877) 357-3317. If you would like to contact us via email please click here.
Copyright ©2025 National Law Forum, LLC