BIGGER FISH?: Dobronski Wins Critical Caller ID Issue Even As He Loses His Case

What a headache.

You’ll recall a guy named Dobronski– who really is a headache– has opened up an entirely new avenue to sue telemarketers. Specifically, he has convinced courts a private right of action exists to enforce 47 CFR Section 64.1601(e).

That section requires marketers to display their caller ID information accurately anytime a carrier provides the ability for the to do so. And at least one court has held the rule also applied to SMS messages! (Crazy.)

CRITICAL COMPLIANCE ALERT: TCPA Caller ID Rules Pose Massive Risk to Marketers

Well Dobronski actually lost this argument recently in front of a magistrate judge, but the district court refused to adopt that portion of the report– meaning TCPAWorld just lost one of the few recent rulings dismissing these caller ID claims. And what’s weird is that this “win” came in the context of an otherwise complete loss by Dobronski.

In Dobronski v. Julias Angel Marketing, 2025 WL 2659265 (E.D. Mich. Sept. 17, 2025) the district court considered Dobronski’s myriad objections to a magistrate judge’s ruling in the defendant’s favor.

Backing up, many courts assign motions to magistrate judges–essentially smart lawyers who serve as specially-appointed judges for the court– for discovery and non-dispositive rulings. The parties can also agree to have entire cases heard in front of an MJ, who tend to be less busy than the federal judges.

But when an MJ makes a rulng a party can make objections to the ruling and have them heard by the district court judge– and that’s what happened here. The MJ ruled against Dobronski on everything–including the Section 64.1601(e) issue– and he objected.

The district court agreed with the MJ on just about everything– meaning that Dobronski’s case got tossed– BUT it refused to adopt the MJ’s conclusion that no private right of action existed for Section 64.1601(e):

Having found that Plaintiff fails to plead direct or vicarious liability under the TCPA against moving Defendants, the Court need not address whether there is a private right of action for alleged violations of § 64.1601(e). In fact, principles of judicial restraint compel this Court to be reluctant in dealing with the thorny question of whether there is a private right of action for alleged violations of § 64.1601(e). See Cent. Bank of Denver, N.A. v. First Interstate Bank of Denver, N.A., 511 U.S. 164, 201 (1994) (Stevens, J., dissenting) (“we are … properly reluctant to recognize private rights of action without an instruction from Congress”); see, e.g., Diering v. Reg’l W. Med. Ctr., No. 06-5010, 2006 WL 8458251, at *3 (D. Neb. Sept. 15, 2006) (“under the principles of judicial restraint, the Court declines to find that [the section in question] provides for a private right of action”). Therefore, the Court DECLINES TO ADOPT this portion of Judge Patti’s Report and Recommendation and OVERRULES Plaintiff’s fourth objection as moot.

So, yeah. Can’t rely on that ruling anymore.

Overall a nice in for defendants here– but TCPAWorld needs to remain vigilant on the caller ID claims.

Give Troutman Amin, LLP a call sometime in the next couple of months. Our rates are jumping January 1, 2026 and you don’t want to be the company that pays more than you needed to for great representation. (Although it will still be well worth it even under the new 2026 rate structure.)

Chat soon.