The Northern District of Alabama recently followed the Second Circuit's holding in Reyes v. Lincoln Automotive Financial Services, 861 F.3d 51 (2d Cir. 2017), and held that consent provided in a contract as part of a bargained-for exchange could not be unilaterally revoked under the TCPA. With this holding, the Northern District of Alabama becomes the first court in the Eleventh Circuit to follow Reyes.
In Few v. Receivables Performance Management, No. 1:17-CV-2038-KOB, 2018 WL 3772863 (N.D. Ala. Aug. 9, 2018), Plaintiff alleged that Defendant violated the TCPA by calling and ...