If you're running both an outbound calling campaign and a texting campaign to the same lead list, you've probably already hit this question: a lead texts back "STOP" to your SMS, and your dialer is still scheduled to call that same number tomorrow. Does the text opt-out cover the calls, or are they two separate consent buckets?
A federal court in Florida just answered that question, and the answer complicates a rule of thumb a lot of operators have been leaning on.
A Court Just Ruled a Text STOP Can Kill Your Calls Too
In Zagury v. Puragin Water, 2026 WL 2299332 (S.D. Fla. Aug. 11, 2026), the plaintiff replied "stop" to a marketing text. The defendant didn't dispute that this killed consent for future texts. It argued the calls could keep going, because the revocation was sent on the SMS channel and should only bind that channel.
The court rejected that. It held that once a consumer says "stop" to a text, a business has to treat both the calls and the texts as revoked, unless it sends a one-time confirmation text asking the consumer to clarify that the revocation is SMS-only and the consumer agrees. Absent that clarification, silence doesn't save you. You're expected to stop calling.
This is a class action ruling on a motion to dismiss, not a final judgment on the merits, and it's one district court, not binding nationwide. But it's consistent with where TCPA revocation law has been heading for a while, and it tells you how at least one federal judge is going to read a "STOP" reply when a plaintiff's firm brings the next version of this case.
The Rule the Court Cited Isn't Actually in Effect Yet
Here's the part that didn't make it into most of the coverage: the court leaned on the FCC's "revoke-all" provision, 47 C.F.R. § 64.1200(a)(10), which extends a revocation made on one channel, or for one purpose, to every future call and text from that caller. That provision is real but not yet binding. The FCC has pushed its effective date twice, most recently to January 31, 2027, a delay we walked through in what actually counts as an SMS opt-out.
Attorney commentary on the Zagury opinion flagged this directly: the court "cited a portion of the FCC's rule ... that is not yet in effect," meaning the so-called nuclear revocation rule, and "noted that certain portions of the FCC's revocation rule have been delayed but, for some reason, concluded this portion of the rule was not." In plain terms, the judge cited a rule as current law when it's actually on hold until 2027.
Don't read that as a loophole. It cuts the other way. If a federal court is willing to reach a cross-channel revocation result under a rule that isn't even active, betting your compliance program on the delay is a bad bet. The reasoning the court actually needed was already available before this rule existed.
What's Already Binding, Delay or No Delay
Separate from the delayed revoke-all provision, the FCC's 2024 consent-revocation order made several things effective on April 11, 2025, and they're still in force:
- Consumers can revoke consent through "any reasonable method," including replying with common keywords. STOP, QUIT, END, CANCEL, UNSUBSCRIBE and similar terms are treated as per se reasonable.
- A business cannot designate one exclusive channel or method for revocation. If the consumer used a reasonable method, that's enough, even if it isn't the one you'd have picked.
- Revocation requests have to be honored within a reasonable time, not to exceed 10 business days.
That "any reasonable method" language traces back further than the 2024 order, to the FCC's 2015 TCPA rules, which already directed courts to weigh the "totality of the circumstances" when a consumer's revocation didn't fit a business's preferred format. Zagury's outcome is defensible under that older, currently-effective standard on its own. The court cited the wrong rule number, but the underlying legal theory it needed to reach the same conclusion was already sitting there. This is why "the revoke-all rule doesn't kick in until 2027" is not a safe compliance position today.
The Money Behind This Isn't Hypothetical
TCPA plaintiffs' firms don't need a new theory to make this expensive. LendingTree's QuoteWizard subsidiary paid $19 million to settle a TCPA class action over unwanted texts, and as of a new complaint filed in July 2026, it's back in court. The new suit alleges the company kept texting a consumer after she replied "unsubscribe," from a number using what the complaint calls a fabricated sender name. That's a same-channel violation: texting after a text opt-out. A cross-channel version of the same fact pattern, texting stop and then continuing to call, is a straightforward next step for the same plaintiffs' bar, and Zagury is the opinion they'll cite when they file it.
Building One Suppression List Instead of Two
If your calls and your texts run through different systems, a dialer here, a texting platform there, the practical risk isn't the legal theory. It's the seam between the two tools. The consumer said stop once. Whether your business honors that depends on whether the suppression flag actually reaches both systems.
A few things worth doing regardless of what the FCC's calendar says:
- Treat any STOP-family reply on any channel as a signal to suppress that number everywhere you contact them, not just on the channel it arrived on, unless you've built the clarification step Zagury describes and the consumer has actually confirmed a narrower scope.
- Log the method, channel, timestamp, and exact text of every revocation. If a case turns on "totality of the circumstances," your records are the evidence.
- If you genuinely need to keep one channel open, for example a required non-marketing account update, don't assume that. Send the one-time clarification text the court described and get an affirmative answer before you rely on it.
- Don't wait for January 31, 2027. Whatever process you'd build for the FCC's revoke-all rule, current case law already gives plaintiffs a path to the same outcome.
Where Android Texter Fits
Android Texter routes SMS as person-to-person traffic through a phone you own, which means it isn't gated by A2P 10DLC's business-messaging rules the way a Twilio-style aggregator is. That's a carrier-classification issue, not a TCPA one. Nothing about how a message gets delivered changes who has to honor a "stop." That responsibility is yours either way.
What the platform does handle is the mechanical part of honoring it on the SMS side: auto-reply rules recognize STOP-family keywords and return a confirmation while suppressing the number, so a text opt-out doesn't depend on someone manually catching it in the inbox. If your calling system is separate, that suppression event needs to reach it too. SMS forwarding rules and the webhook API let you mirror an inbound opt-out message into whatever system runs your calls, so the number gets suppressed there as well instead of staying live in a dialer that never sees the text thread. It won't tell you whether a specific number needs to stay suppressed on the call side under Zagury, that's a legal judgment for you or your counsel, but it closes the gap where a text opt-out dies inside one tool instead of reaching all of them.
Frequently Asked Questions
Does replying STOP to a text legally stop phone calls too?
Under Zagury v. Puragin Water, at least one federal court says yes, unless you send a one-time confirmation text and the consumer agrees the revocation is text-only. This is one district court decision on a motion to dismiss, not a nationwide rule, but it reflects how courts are currently reading TCPA revocation.
Is the FCC's "revoke-all" rule actually in effect right now?
No. The cross-channel provision at 47 C.F.R. § 64.1200(a)(10) has been delayed twice and is currently set to take effect January 31, 2027. Other parts of the FCC's 2024 revocation order, including the per se reasonable revocation methods and the 10-business-day honor window, have been in effect since April 11, 2025.
What counts as a valid way for someone to revoke consent?
Any reasonable method that clearly communicates they don't want further contact. Replying STOP, QUIT, END, CANCEL, or UNSUBSCRIBE to a text is per se reasonable. You cannot require consumers to use only one specific channel or format to opt out.
Can I text a customer to ask if their STOP request covers calls too?
The Zagury court left this door open: a one-time clarifying text asking whether the revocation is limited to texts, with the consumer's affirmative response, can narrow the scope. Without that confirmation, courts are treating a text STOP as covering calls by default.
Does Android Texter reduce my TCPA exposure?
No, and we don't claim it does. Android Texter changes how SMS is routed, as person-to-person traffic instead of carrier-gated business messaging, which affects deliverability, not your legal obligations. Consent, revocation, and TCPA compliance remain entirely the operator's responsibility.
If you're running calls and texts to the same list and they're not sharing one suppression list, that's the gap to close before the next version of this lawsuit lands. If the SMS side of that is the piece you're missing, Android Texter's auto-reply and webhook tools can at least make sure a text opt-out doesn't get stuck in a dashboard nobody else sees.