On July 8, 2019, one month after its decision in Duguid v. Facebook, the Ninth Circuit reasserted its conclusion that the TCPA’s exception for calls made for federal government debt collection purposes was unconstitutional. In Gallion v. Charter Communications, Inc., the court affirmed a lower court’s decision that denied Charter’s motion for judgement on the pleadings that raised a challenge to the TCPA’s constitutionality. Citing its decision in Duguid, the Ninth Circuit held that while the government debt collection exception is unconstitutional under the First Amendment, that portion was separated from the rest of the TCPA so it was appropriate for the lower court to deny Charter’s constitutionality motion.