The Supreme Court (SCOTUS) has granted certiorari in a Fourth Amendment case, Barnes v. Felix, which will address how to determine reasonableness in excessive force cases. Additionally, the Ninth Circuit has reminded everyone that prerecorded voice calls are actionable under the Telephone Consumer Protection Act (TCPA) even without an automatic telephone dialing system (ATDS). In a related development, the Supreme Court will hear a TCPA case involving Hobbs Act deference.