McLaughlin Chiropractic Associates, Inc. v. McKesson Corp., 606 U.S. 146

Background

The Telephone Consumer Protection Act (TCPA) bars sending unsolicited fax advertisements without opt-out notices, giving recipients a private right of action for statutory damages.
McKesson sent unsolicited faxes to medical practices, including McLaughlin Chiropractic Associates, some to traditional fax machines, others through online fax services.
McLaughlin sued McKesson in federal court and sought class certification for all recipients, regardless of fax delivery method.
During litigation, the FCC issued the Amerifactors order, stating the TCPA did not apply to online fax services; the district court, following Ninth Circuit precedent, treated this order as binding.
The Supreme Court was asked whether the Hobbs Act required district courts in civil enforcement proceedings to defer absolutely to an agency’s statutory interpretation, or to independently interpret statutes.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are district courts bound by agency statutory interpretation (under the Hobbs Act)?	District courts should interpret statutes independently, not be bound by FCC orders.	The Hobbs Act gives courts of appeals exclusive jurisdiction; district courts must follow the FCC’s interpretation.	District courts are not bound and must interpret statutes independently, giving appropriate respect to the agency’s views.
Does the Hobbs Act preclude judicial review in enforcement proceedings?	No express statutory preclusion exists, so judicial review must be available in enforcement.	Exclusive appellate jurisdiction precludes subsequent challenges in district court.	The Hobbs Act does not preclude district court review in enforcement cases absent explicit congressional direction.
Should prior, adequate, and exclusive opportunity for review limit later challenges?	Only bars relitigation by same parties; general principles of estoppel apply.	If an opportunity existed, later district court review is barred for everyone.	Only specific, involved parties are precluded under preclusion/estoppel norms, not all subsequent challengers.
Do policy concerns (finality, efficiency) justify preclusion of judicial review?	Fairness and the default APA presumption require access to review in enforcement.	Preclusion is necessary for finality and to avoid regulatory uncertainty.	Policy cannot override statutory text and default administrative law principles supporting district court review.

Key Cases Cited

United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (background on reasoning for headnotes and syllabi)
Mims v. Arrow Financial Services, LLC, 565 U.S. 368 (TCPA confers private right of action in state or federal court)
Abbott Laboratories v. Gardner, 387 U.S. 136 (pre-enforcement review, presumption of judicial review, and expansion to enforcement challenges)
Yakus v. United States, 321 U.S. 414 (pre-enforcement review and the necessity of statutory clarity for preclusion of further review)
Port of Boston Marine Terminal Ass’n v. Rederiaktiebolaget Transatlantic, 400 U.S. 62 (preclusion of collateral attack when losing party attempts relitigation in another forum)
FCC v. ITT World Communications, Inc., 466 U.S. 463 (limits of collateral challenge to FCC orders under exclusivity statutes)
Cuozzo Speed Technologies, LLC v. Lee, 579 U.S. 261 (presumption against preclusion of judicial review unless clear statutory direction)