Interpreting the Supreme Court’s ruling in Barr v. American Association of Political Consultants, Inc., severing the government-backed debt exception from the Telephone Consumer Protection Act (TCPA), a federal court in Delaware held that a debt collector could be liable under the statute for claims that arose prior to the Court’s decision. The case is Franklin v. Navient, Inc. The plaintiff, Ricky Franklin, claimed that he received 86 calls between 2015 and 2017 from Navient, seeking to collect on his federal government-backed student debt. Navient moved for summary judgment on calls after November 2015, when Congress added the exception for government-backed debt to the TCPA.