Canady v. Bridgecrest Acceptance Corporation

CourtDistrict Court, D. Arizona
DecidedJanuary 21, 2022
Docket2:19-cv-04738
StatusUnknown

This text of Canady v. Bridgecrest Acceptance Corporation (Canady v. Bridgecrest Acceptance Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Canady v. Bridgecrest Acceptance Corporation, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Tonya Canady, No. CV-19-04738-PHX-DWL

10 Plaintiff, ORDER

11 v.

12 Bridgecrest Acceptance Corporation,

13 Defendant. 14 15 INTRODUCTION 16 In this putative class action, Plaintiff Tonya Canady (“Canady”) alleges that 17 Defendant Bridgecrest Acceptance Corporation (“Bridgecrest”) violated the Telephone 18 Communications Protection Act, 47 U.S.C. § 227 et seq. (“TCPA”), by placing calls to her 19 cell phone throughout 2018 and 2019 without her consent while using an artificial or 20 automated voice. (Doc. 1.)1 Such calls are often referred to as robocalls. 21 In 2020, while this case was pending, the Supreme Court decided Barr v. Am. Ass’n 22 of Political Consultants, Inc., 140 S. Ct. 2335 (2020). In Barr, a group of “organizations 23 that participate in the political system” filed a declaratory judgment action in which they 24 argued that § 277(b)(1)(A)(iii) of the TCPA—the same provision Bridgecrest is accused of 25 violating in this case—is unconstitutional. Id. at 2344-45. The plaintiffs’ theory was that 26 because Congress had amended the TCPA in 2015 to add an exception that authorized 27 1 The complaint also alleges that Bridgecrest violated the TCPA by using an 28 automatic telephone dialing system (“ATDS”) when making the challenged calls (Doc. 1 ¶ 37), but Canady has since clarified that she will not be pursuing that allegation (Doc. 83). 1 robocalls for one specific purpose (i.e., collecting government debt), the addition of this 2 exception meant that the post-2015 version of the TCPA favored some categories of speech 3 over others, in violation of the First Amendment, and the only remedy was “to invalidate 4 the entire robocall restriction.” Id. at 2346. Although the Supreme Court agreed with the 5 plaintiffs that “the 2015 government-debt exception created an unconstitutional exception 6 to the . . . robocall restriction,” it rejected the plaintiffs’ proposed remedy, holding that “the 7 correct result in this case is to sever the 2015 government-debt exception and leave in place 8 the longstanding robocall restriction.” Id. at 2348-55. 9 Based in part on Barr, Bridgecrest has now filed a motion for judgment on the 10 pleadings. (Doc. 62.) In a nutshell, Bridgecrest argues that (1) the TCPA is 11 unconstitutional in its present form because it contains seven additional content-based 12 exceptions that were not addressed in Barr, none of which survives strict scrutiny, and the 13 exceptions cannot be severed, both because they differ from the single exception that was 14 severed in Barr and because the appellate courts possess exclusive jurisdiction to entertain 15 challenges to some of the exceptions; and (2) alternatively, the TCPA was unconstitutional 16 between 2015 (when the government-debt exception was enacted) and July 2020 (when it 17 was severed in Barr), so no liability can arise from the alleged violations in this case 18 because they occurred during the period of unconstitutionality. (Id.) Bridgecrest’s motion 19 is opposed not only by Canady (Doc. 71) but also by the United States, which has 20 intervened for the limited purpose of defending the TCPA’s constitutionality (Doc. 79). 21 For the following reasons, the Court rejects Bridgecrest’s challenges to the TCPA 22 and denies its motion for judgment on the pleadings. 23 STANDARD OF REVIEW 24 A motion for judgment on the pleadings under Rule 12(c) is “functionally identical” 25 to a Rule 12(b)(6) motion to dismiss. United States ex rel. Cafasso v. Gen. Dynamics C4 26 Sys., Inc., 637 F.3d 1047, 1054 n.4 (9th Cir. 2011). Therefore, a Rule 12(c) motion “is 27 properly granted when, taking all the allegations in the non-moving party’s pleadings as 28 true, the moving party is entitled to judgment as a matter of law.” Fajardo v. Cnty. of Los 1 Angeles, 179 F.3d 698, 699 (9th Cir. 1999). “For purposes of the motion, the allegations 2 of the non-moving party must be accepted as true, while the allegations of the moving party 3 which have been denied are assumed to be false.” Hal Roach Studios, Inc. v. Richard 4 Feiner & Co., 896 F.2d 1542, 1550 (9th Cir. 1989).2 5 DISCUSSION 6 I. The TCPA In Its Present Form 7 A. The Parties’ Arguments 8 Bridgecrest argues that § 227(b)(1)(A)(iii) of the TCPA “remains unconstitutional 9 to this day” because Barr only addressed the ramifications of one content-based exception 10 to its general prohibition against robocalls (i.e., the government-debt exception) and did 11 not consider the constitutional ramifications of the following seven additional content- 12 based exceptions and restrictions: (1) the exception for emergency calls codified within 13 § 277(b)(1)(A)(iii); (2) an exception created by the Federal Communications Commission 14 (“FCC”) for “autodialed or prerecorded message calls by a wireless carrier to its customer 15 when the customer is not charged”; (3) an FCC-created exception for certain healthcare- 16 related calls; (4) an FCC-created exception for certain package-delivery notifications; (5) 17 an FCC-created exception for schools to communicate with students and parents; (6) an 18 FCC-created exception for certain messages by banks pertaining to fraud; and (7) an FCC- 19 created restriction requiring a higher level of consent for calls made for a marketing 20 purpose than calls made for an informational purpose. (Doc. 62 at 6-7.) Bridgecrest 21 contends that none of these exceptions and restrictions survives strict scrutiny (although

22 2 Although Bridgecrest argues that is entitled to judgment on the pleadings due to a lack of subject-matter jurisdiction, the Court views Bridgecrest’s arguments as better 23 characterized as being based on the lack of a plausible claim for relief. Cf. Lindenbaum v. Realgy, LLC, 13 F.4th 524, 527 (6th Cir. 2021) (“Realgy moved to dismiss for lack of 24 subject-matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1), but its motion ‘is more accurately considered a Rule 12(b)(6) motion to dismiss for failure to state a 25 claim.’ After all, a district court has jurisdiction when ‘the right of the petitioners to recover under their complaint will be sustained if the Constitution and laws of the United States 26 are given one construction and will be defeated if they are given another.’ That is the case here. If Lindenbaum’s arguments about the continuing vitality of the robocall restriction 27 from 2015 to 2020 are correct, she is entitled to relief. So we will treat the district court’s dismissal as one under Rule 12(b)(6) . . . .”) (citations omitted). See also Sagers v. Arizona 28 State Univ., 2021 WL 4894318, 3 n.*3 (D. Ariz. 2021) (same). This clarification does not change the outcome—Bridgecrest’s motion would be denied either way. 1 the exception for emergency calls may “come close”), so their presence “renders the TCPA 2 a content-based restriction on speech that runs afoul of basic First Amendment principles.” 3 (Id. at 7-8.) As for the possibility of severance, Bridgecrest acknowledges that Barr held 4 that the First Amendment concerns arising from the presence of a “single content-based 5 exception” could be resolved through severance but argues that “nothing in the [Barr] 6 ruling mandates that a statute containing numerous content-based exceptions should 7 always survive constitutional scrutiny.” (Id.

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Canady v. Bridgecrest Acceptance Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/canady-v-bridgecrest-acceptance-corporation-azd-2022.