TCPA Win for SMS Opt-Out LimitsStamper v. Manus Ruling

If you run SMS marketing campaigns, the phrase “reply STOP to unsubscribe” is probably burned into your brain.
But what happens when a business adds a twist, like “reply STOP to end this type of message” and “reply STOPALL to
stop all messages”? That’s exactly the situation at the center of Stamper v. Manus-Northwestern Oral Health Center, Ltd.,
a 2025 decision that gave businesses a short-term Telephone Consumer Protection Act (TCPA) win on SMS opt-out limits
even as new FCC rules are moving in a more consumer-friendly direction.

In this article, we’ll break down what happened in Stamper, why the court sided with the sender, how this fits
alongside new TCPA opt-out rules, and what practical steps brands should take to keep their SMS programs compliant
without killing their ability to communicate with customers.

TCPA and SMS Opt-Outs: Why This Case Matters

The Telephone Consumer Protection Act (TCPA) is the main federal law governing automated calls and texts to consumers.
Over the last decade, it has turned text message marketing into a legal minefield. Under the TCPA and FCC rules,
businesses generally must:

• Obtain valid consent before sending promotional texts.
• Clearly tell people how to stop receiving messages.
• Honor opt-out requests within a short, reasonable time frame.

Historically, regulators and courts have leaned toward a consumer-friendly approach: if a person reasonably
communicates “I don’t want these texts,” businesses should stop sending them. Recently, the FCC codified that
consumers can revoke consent in “any reasonable manner” and that businesses can’t require overly complicated or
exclusive opt-out methods like multi-step forms or obscure keywords.

Against that background, Stamper v. Manus stands out because the court allowed a business to treat a
“STOP” message as a limited opt-out rather than a total shutdown of all texts from that sender. For brands juggling
multiple messaging streams (reminders, promotions, alerts), this is a big deal.

What Happened in Stamper v. Manus?

The relationship and message flow

In Stamper, the plaintiff had agreed to receive text messages from a dental provider, Manus-Northwestern Oral Health Center.
Over time, the provider sent a variety of texts: appointment reminders, recall messages, and other communications. Some
texts were even tied to different individuals who used the plaintiff’s phone number as the contact numberfor example,
family members or dependents.

Each text message included opt-out instructions. But there was a twist:

• Reply “STOP” to stop messages about a specific topic or patient.
• Reply “STOPALL” to stop all communications from the provider.

The plaintiff replied “stop” multiple times, believing that this should have been enough to end all texts from the provider.
Despite those replies, additional messages continued to arrive, particularly on other topics or for other patients linked
to the same phone number.

The TCPA lawsuit

The plaintiff sued under the TCPA, arguing that the “stop” replies should have revoked consent for all SMS communications,
not just the specific thread. In her view, “STOP means STOP”full stop.

The defendant disagreed. It argued that it had:

• Honored the “STOP” text for the particular message stream it related to, and
• Clearly explained in its messages that “STOPALL” was required to end all texts.

Since the plaintiff never sent “STOPALL,” the provider maintained that it was allowed to continue sending other,
different categories of messages without violating the TCPA.

How the Court Read “STOP” vs. “STOPALL”

Clear and reasonable communication is the key

The core legal question was whether the plaintiff’s “stop” messages were a clear and reasonable attempt to revoke
consent to all communicationsor just the specific campaign she replied to.

The court focused on existing FCC rules requiring that opt-out requests be “reasonable” and “clear,” but not dictating
exact magic words or formats. Because the plaintiff had:

• Subscribed to at least two different types of text communications, and
• Used a phone number as the contact point for multiple individuals,

the court concluded that it would not be reasonable to assume a single “stop” necessarily meant “stop everything for
every person and every topic.”

Instead, the court held that:

The “STOP” text clearly revoked consent to the specific type of message the plaintiff had just received for the
patient named in that message, but it did not clearly communicate a desire to unsubscribe from all texts from the provider.

Because the business had clearly explained the difference between “STOP” and “STOPALL,” and because the plaintiff
didn’t follow the broader “STOPALL” instruction, the court found that the defendant’s limited interpretation of the opt-out
was reasonable and TCPA-compliant.

Following earlier case law

The court in Stamper relied in part on earlier case law, including Michel v. Credit Protection Association, where
revocation of consent applied to a specific debt account but not to all accounts the consumer had with the same company.
In both cases, judges treated different streams of communication (different accounts, different patients, or different
topics) as separate enough that a single generic opt-out didn’t automatically cancel everything.

But WaitNew FCC Opt-Out Rules Are More Consumer-Friendly

At first glance, Stamper might look like a green light for very granular opt-out schemes. But things are more complicated
because the FCC has adopted new rules that significantly strengthen consumers’ rights to revoke consent.

“Any reasonable manner” to opt out

Under the FCC’s 2024–2025 updates, consumers can revoke consent to robocalls and robotexts in any reasonable manner.
Replying with standard words like “STOP,” “QUIT,” “END,” “REVOKE,” “CANCEL,” or “UNSUBSCRIBE” is explicitly listed as a
valid way to opt out. Businesses are not allowed to limit consumers to narrow, exclusive pathways for revocation.

On top of that, industry guidance and compliance checklists increasingly stress that:

• Opt-outs should be simple, one-step processes.
• Consumers should be able to stop text messages by sending a single, clear keyword like “STOP.”
• Businesses must process opt-out requests quicklyoften within 24 hours or, under some new standards, no more than 10 business days.

That consumer-friendly direction doesn’t erase Stamper, but it does suggest that businesses relying too heavily on
highly segmented “STOP vs. STOPALL vs. STOPEXACTLYTHISONEPATIENTONLY” logic may find themselves on thinner ice in
future litigation or regulatory scrutiny.

A “temporary” win for granular opt-out schemes

Legal commentators have described Stamper as a temporary victory for businesses using layered opt-out
instructions. Why temporary? Because as the new FCC rules take full effect and more courts apply them, there’s growing
pressure to interpret common keywords like “STOP” broadlyoften as revoking consent to all automated texts from that
sender, not just one campaign.

In other words, Stamper shows what’s possible when a court gives weight to detailed opt-out instructions. But it may not
be a long-term blueprint, especially if your SMS strategy pushes the boundary between “helpful segmentation” and
“confusing legal trap.”

Compliance Takeaways for SMS and Text Marketing Programs

So what should brands actually do in light of Stamper and the new TCPA/FCC environment? Here are practical tips:

1. Keep opt-out language simple and obvious

Even though Stamper upheld the “STOP vs. STOPALL” distinction, most compliance experts still recommend a single,
easy keywordusually “STOP”to opt out of marketing texts. Many industry guidelines and CTIA/TCPA best practices
explicitly expect that consumers can simply reply “STOP” and be removed.

If you must use more granular options:

• Make the difference between them crystal clear.
• Avoid burying explanations in dense fine print.
• Consider treating a plain “STOP” as a global opt-out, even if your terms technically allow a narrower reading.

2. Map your message streams and consent

Stamper turned in part on the fact that multiple patients and message types were tied to one phone number. That’s a
common reality for healthcare, schools, and family accountsbut it creates complexity. Conduct a quick audit:

• How many types of messages do you send to the same number (promos, alerts, reminders, billing, etc.)?
• Do you track consent separately for each category?
• If someone texts “STOP,” what exactly happens in your systemfor all categories and all related profiles?

The more tangled your messaging tree, the more conservative your opt-out rules should be.

3. Honor opt-outs fastpreferably in real time

Courts and regulators generally view delays skeptically. Recent decisions and compliance guidance suggest that honoring
opt-outs within a very short timeframesometimes as little as 24 hours, and in any case well under 10 business daysis
now the expectation.

From a customer experience standpoint, nothing feels spammy faster than getting multiple messages after you’ve
clearly opted out.

4. Train your teams and tune your automation

Even the best policy is useless if your people and platforms don’t follow it. Make sure:

• Your SMS platform correctly interprets common opt-out words (including misspellings and close variants).
• Customer-facing teams (support, sales, front desk) know how to handle in-person or phone opt-out requests.
• Your legal and marketing teams review new campaigns before launch for TCPA compliance.

Remember: under the TCPA, mistakes can be expensive, with statutory damages stacking quickly when messages go to
thousands of recipients.

What This Means for Consumers

Consumers might read Stamper and worry that businesses can play word games with “STOP” and “STOPALL.” In practice,
the trend is moving the opposite way. The FCC’s “any reasonable manner” rule and widespread industry adoption of simple
one-word opt-outs are designed to make it easiernot harderto escape unwanted texts.

If you’re a consumer:

• Keep using clear opt-out words like “STOP,” “UNSUBSCRIBE,” or “CANCEL.”
• Take screenshots of your opt-out messages if you think you may need proof later.
• If the texts keep coming, you may have options under the TCPA, especially as new rules take hold.

Experiences and Lessons from the TCPA Opt-Out Trenches

To bring all of this down from the legal clouds, it helps to look at real-world patterns that often show up in TCPA
disputes and compliance reviews. While details are usually anonymized, the themes are remarkably consistent.

Experience 1: The helpful reminder that turned into “spam”

Imagine a healthcare practice that starts with appointment reminders only. Patients love itno more missed cleanings
or checkups. Over time, marketing gets involved and adds recall messages (“You’re due for a visit!”), promotions
(“Whitening special this month!”), and seasonal campaigns.

Technically, the practice updates its consent language. But in reality, patients mostly remember that they agreed to
“appointment reminders,” not what they see as marketing. A patient finally replies “STOP” after a promotional text,
assuming that everything will stop. Meanwhile, the system is configured to treat that “STOP” as applying only to the
promotional stream, not reminders. The patient keeps getting reminders, gets annoyed, and starts talking to a lawyer.

Stamper suggests that, in some fact patterns, a court might side with the practice if its instructions and segmentation
are clear. But post-rule-change, many organizations are deciding it’s just not worth the risk. They now treat “STOP” as
a universal kill switch for anything that isn’t strictly required or legally mandated. If they truly need a separate
channel (for example, urgent safety alerts or care coordination), they build and document that distinction extremely
carefullyand usually still offer an easy opt-out if possible.

Experience 2: The family phone number problem

Another repeating theme is the “one number, many people” issue. Parents use their own phone numbers for their kids’
schools, doctors, sports leagues, and extracurriculars. A parent might receive texts for three different children,
two clinics, and a school districtall to the same device.

When that parent replies “STOP” to a message about one child’s dental appointment, what should happen? In Stamper, the
court was comfortable with the idea that a single opt-out applied just to the particular thread and patient referenced
in the message. That makes technical sense, but it’s easy to see how a reasonable person might think “STOP” means “I’m
done getting this organization’s texts, period.”

The experience of families like this has pushed many organizations to rethink how they label messages and opt-out flows.
Some now include the patient or child’s name in every message header and explicitly confirm which person you’ve opted out
for when you send “STOP.” Others send a polite follow-up: “You’ll no longer receive texts for Alex. To stop all texts
from us for any family member, reply STOPALL.” That kind of clarity can reduce both confusion and legal exposure.

Experience 3: The over-engineered compliance system

On the other side of the spectrum are companies that try to engineer compliance so tightly that the user experience
becomes painful. They might require customers to click a link in every message, log into a portal, navigate to a
“communications preferences” page, select the right checkboxes, and confirm changesjust to stop texts.

These setups often look great in internal compliance memos (“We have robust preference management!”), but they age
badly once regulators and courts weigh in. FCC guidance and TCPA best practices increasingly stress that opt-outs
should be quick, simple, and usable from within the channel itselfmeaning a one-word text reply should usually be
enough.

Companies that learned this lesson the hard way have started simplifying aggressively. They still maintain preference
centers for people who want fine-grained control, but they treat a “STOP” reply as an override. If a consumer goes out
of their way to tell you to stop, the safest and most customer-friendly answer is to listen.

Experience 4: The AI-powered campaign that forgot about TCPA

As more brands deploy AI-driven SMS tools, another pattern is emerging: the AI is great at sending personalized,
behavior-based messagesbut it’s terrible at remembering legal guardrails unless humans build them in from the start.
Without proper configuration, AI tools may send follow-up texts to people who already opted out, misinterpret free-form
“please stop texting me” replies, or fail to record revocations in central systems where compliance teams expect them.

Organizations that have successfully avoided TCPA disasters with AI almost always follow the same playbook: they give
their AI tools very strict rules about consent and opt-outs, build robust logging, and run regular audits to confirm that
every “STOP” (or similar message) actually shuts off the message stream. TCPA compliance is woven into the AI strategy,
not bolted on later.

Bottom Line: Don’t Let a Short-Term Win Become a Long-Term Risk

The Stamper v. Manus ruling is a meaningful TCPA win for SMS opt-out limitsat least for now. It confirms that,
under certain facts, businesses can distinguish between narrow and global opt-outs if they clearly explain the difference
and respect the scope of each request.

But this decision lives in a fast-evolving landscape. New FCC rules, stronger enforcement, and industry best practices
are pushing hard toward:

• Simple, one-step opt-outs.
• Broad interpretations of common words like “STOP.”
• Faster turnaround times when customers revoke consent.

If you’re responsible for SMS marketing or automated messaging, the safest strategy is to treat Stamper as a helpful
data pointnot a license to get clever with opt-out gymnastics. Design your programs as if a court will assume
“STOP” means “stop everything,” and then build your segmentation, technology, and training around that assumption.

You’ll protect your brand, reduce litigation risk, and build more trust with the people whose phones you’re trying to
reachwhich, in the long run, is the best compliance strategy of all.