Insights

Washington, D.C. – July 17, 2023: Crowell & Moring hosted its 24thannual George Bailey Public Service Awards ceremony. Named after the hero of the classic movie, “It’s a Wonderful Life,” these awards recognize the firm’s lawyers and staff who have made a substantial impact on the lives of others.

On July 24, 2023, an en banc Eleventh Circuit joined the majority of circuits to find that just one text is sufficient to establish standing to bring a Telephone Consumer Protection Act (“TCPA”) claim. The decision, Drazen v. Pinto, --- F.4th ---, 2023 WL 4699939 (11th Cir. July 24, 2023), not only undoes the panel’s original holding, but also reverses course from the Eleventh Circuit’s prior decision in Salcedo v. Hanna, 936 F.3d 1162 (11th Cir. 2019), which held that a Plaintiff who received a single text message did not have TCPA standing.