Well, well, well—McLaughlin Chiropractic v. McKesson has truly stirred up the legal landscape—or better yet, shaken an imbalanced tower of FCC interpretations and court splits surrounding one of the most litigated federal statutes: our beloved TCPA. And TCPAWorld is no stranger to this ever-shifting landscape—or the tangled web of regulations that define both compliance and the defense of what has become a cash cow of litigation.

In McLaughlin Chiropractic v. McKesson, the Supreme Court held that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency’s interpretation of a statute. Rather district courts must independently determine the law’s meaning under ordinary principles of statutory interpretation while affording appropriate respect to the agency’s interpretation. And for companies navigating the FCC’s STIR/SHAKEN framework under the TRACED Act, that’s a big deal.

The TRACED Act (Telephone Robocall Abuse Criminal Enforcement and Deterrence Act) was Congress’s response to the flood of illegal robocalls and spoofed caller IDs. It gave the FCC stronger enforcement tools and required STIR/SHAKEN (Secure Telephone Identity Revisited and Signature-based Handling of Asserted Information Using toKENs) protocols, which require voice service providers to digitally sign and verify caller ID information, making it harder for bad actors to disguise their numbers..

Until now, challenging the FCC’s interpretation of the TRACED Act or its implementation of STIR/SHAKEN was considered nearly impossible at the district court level. The Hobbs Act gave federal court of appeals exclusive jurisdiction to review FCC orders, and many courts treated the agency’s interpretations as binding—regardless of context.

That’s where McLaughlin makes a difference because district courts now have greater freedom to evaluate how the FCC reads and applies the TRACED Act.

This shift is particularly important in litigation involving STIR/SHAKEN. McLaughlin opens the door to as-applied challenges in enforcement actions or private lawsuits. If you’re being sued, the district court can evaluate the FCC’s interpretation of the TRACED Act. Since the TRACED Act is a statute passed by Congress, it is not easily challenged unless there’s a constitutional issue. But how that statute is interpreted and enforced—especially through FCC rules like STIR/SHAKEN—is very much in play.

In the end, McLaughlin clarifies that courts have a duty to interpret statutes for themselves, not simply follow the agency’s lead. And in the TCPA landscape where regulatory rules can dictate millions in liability, it’s critical.