The late Senator Fritz Hollings, the sponsor of the Telephone Consumer Protection Act of 1991 (TCPA, codified at 47 U.S.C. §227), offered this justification for the statute, which prohibits the use of unsolicited, nonconsensual autodialed phone calls, texts, and faxes: “Computerized calls are the scourge of modern civilization. They wake us up in the morning; they interrupt our dinner at night; they force the sick and elderly out of bed; they hound us until we want to rip the telephone right out of the wall.”

Although in the 25 years since the TCPA’s passage, far fewer people now use phones affixed to a wall, unwanted telemarketing remains a vexing problem. See Mims v. Arrow Financial Services, 132 S. Ct. 740 (2012) (noting that the TCPA is a response to “[v]oluminous consumer complaints about abuses of telephone technology”). According to a bill introduced on June 5 by Senator Charles Schumer that would outlaw all “robocalling,” New York City’s 917 and 347 area codes received 50 million such calls in April 2016 alone.