Saunders v. Dyck O'Neal, Inc.

CourtDistrict Court, W.D. Michigan
DecidedFebruary 19, 2025
Docket1:17-cv-00335
StatusUnknown

This text of Saunders v. Dyck O'Neal, Inc. (Saunders v. Dyck O'Neal, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Saunders v. Dyck O'Neal, Inc., (W.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

KAREN SAUNDERS,

Plaintiff, Case No. 1:17-cv-335 v. HON. ROBERT J. JONKER DYCK-O’NEAL, INC.,

Defendant. ____________________________/

OPINION AND ORDER As part of its debt collection efforts, Defendant Dyck O’Neal, Inc. contracted with a vendor called VoApp to leave prerecorded “direct drop” voicemails on debtor’s phones. After receiving one of these voicemails, Plaintiff Karen Saunders filed this suit under the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227. She now moves for class certification and summary judgment. (ECF Nos. 286 and 287). One issue in the briefing is whether Dyck O’Neal can be held liable for initiating or making the call either through direct liability or vicarious liability. For the reasons stated below, the Court holds that Dyck O’Neal can be held liable for initiating the calls in these circumstances. I. BACKGROUND The facts relevant to whether Dyck O’Neal can be held liable for initiating the call are not in dispute. Dyck O’Neal is a debt collection agency and mortgage servicer. In an effort to contact alleged debtors, Dyck O’Neal contracted with VoApps for a direct drop voicemail service. Under the contract, VoApps warranted that the voicemails were compliant with current law and were not regulated under the TCPA. (ECF No. 294-4 at PageID.4058). However, the contract also provided that either party could terminate the agreement if a court of competent jurisdiction determined that the voicemail system violated the TPCA. (Id. at PageID.4055).1 To complete the direct drop voicemails, Dyck O’Neal provided VoApps with (1) the telephone number to be contacted, (2) the day and time the voicemails were sent, and (3) the caller

ID number to be used. Dyck O’Neal also selected the message to be played. For example, one script of the voicemail message provided: “This is Dyck O’Neal with a message. This is an attempt to collect a debt. Please do not erase this message, and will you call us at 1-877-425-8998. Again, that number is 1-877-425-8998.” (ECF No. 294-8 at PageID.4091). II. LEGAL STANDARD Summary judgment “shall” be granted “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). Once the moving party demonstrates that “there is an absence of evidence to support the nonmoving party’s case,” the non-moving party “must identify specific facts that can be established by admissible evidence, which demonstrate a genuine issue for trial.” Amini v. Oberlin

Coll., 440 F.3d 350, 357 (6th Cir. 2006). While the Court must view the evidence in the light most favorable to the non-moving party, the party opposing the summary judgment motion “must do more than simply show that there is some metaphysical doubt as to the material facts.” Id. The existence of a mere “scintilla of evidence” in support of the non-moving party’s position is insufficient. Daniels v. Woodside, 396 F.3d 730, 734-35 (6th Cir. 2005).

1 The Court previously held in this case that the direct drop voicemails are calls under the TCPA. (ECF No. 50 at PageID.504). III. ANALYSIS The TCPA prohibits any person within the United States from “mak[ing] any call . . . using any automatic telephone dialing system or an artificial or prerecorded voice . . . to any telephone number assigned to a paging service, cellular telephone service . . . or any service for which the

called party is charged for the call.” 47 U.S.C. § 227(b)(1)(A)(iii). A principal can be held directly or vicariously liable for violations of the TCPA. Keating v. Peterson’s Nelnet, LLC, 615 F. App’x. 365, 371 (6th Cir. 2015) (citing In re DISH Network, LLC, 28 FCC Rcd. 6574 (2013)). Dyck O’Neal argues that it cannot be held directly liable because it did not send the messages, and any involvement was limited to performing clerical functions. Dyck O’Neal further argues that it is not vicariously liable for VoApps’ calls. Plaintiff disagrees and contends Dyck O’Neal is liable under either theory. The Court addresses each in turn. A. Direct Liability A defendant who “initiates” a call is “directly” liable for TCPA violations that occurred during the call. In re DISH Network, 28 FCC Rcd. at 6583. “[A] person or entity ‘initiates’ a

telephone call when it takes the steps necessary to physically place a telephone call, and generally does not include persons or entities, such as third-party retailers, that might merely have some role . . . .” Id. However, sometimes an entity “is so involved in the placing of a specific telephone call as to be directly liable for initiating it — by giving the third party specific and comprehensive instructions as to timing and the manner of the call, for example.” Id. That is the precise situation here. Dyck O’Neal prepared the list of phone numbers, determined the prerecorded message, and controlled when the calls were made. Dyck O’Neal counters that the Court previously held that VoApps—not Dyck O’Neal— made the calls. But this argument misconstrues the previous opinion. The Court was simply describing the process of how the direct drop voicemail system worked. It is undisputed that VoApps physically sent out the calls. Dyck O’Neal’s involvement in the calls, however, was not mere clerical work. It did not simply play a minor role in the causal chain. Dyck O’Neal maintained complete control and total involvement over the calls. Thus, the Court holds that Dyck O’Neal can be held directly liable for the calls.2

B. Vicarious Liability Even if Dyck O’Neal is not directly liable for the calls, it can be vicariously liable under common-law theories of actual authority or apparent authority. 1. Actual Authority An essential element of agency is the principal’s right to control the agent’s actions.” Restatement (Third) Of Agency § 1.01 cmt. f. “An agent acts with actual authority when, at the time of taking action that has legal consequences for the principal, the agent reasonably believes, in accordance with the principal’s manifestations to the agent, that the principal wishes the agent so to act.” Id. at § 2.01.

Dyck O’Neal argues that that it did not control the calls because (1) its instructions to VoApps were minimal, and (2) the contract with VoApps disclaimed any agency relationship. Specifically, Dyck O’Neal contends that it did not authorize VoApps to make any calls in violation of the TCPA. The contract is not dispositive. See ABS Indus, Inc. v. Fifth Third Bank, 333 F. App’x 994, 1000 (6th Cir. 2009) (“[w]hether a relationship is characterized as agency in an agreement between parties or in the context of industry or popular usage is not controlling.”) (quoting Restatement

2 Although the Court holds that Dyck O’Neal can be held liable for initiating the calls, the Court takes no position on the consent issue at this time. (Third) of Agency § 1.02); Krakauer v. Dish Network, LLC, 925 F.3d 643, 661 (4th Cir. 2019) (“At no time, however, have we suggested that a contractual disclaimer was alone dispositive.”). More importantly, Dyck O’Neal’s involvement was not minimal. It decided what phone numbers would be called. It decided what prerecorded voicemail messages would be played. It uploaded

a “campaign” each day, on the day it wanted calls to be made.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Saunders v. Dyck O'Neal, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/saunders-v-dyck-oneal-inc-miwd-2025.