Rocket Mortgage TCPA Case Paused as Court Orders Arbitration Formation Discovery

• Case: Dobronski v. Rocket Mortgage, LLC
• Court: U.S. District Court for the Eastern District of Michigan
• Decision Date: August 10, 2026
• Citation: 2026 WL 2296669
• Law: Telephone Consumer Protection Act (TCPA); Federal Arbitration Act (FAA)
• Key Issue: Whether the plaintiff or someone acting for him submitted an online mortgage inquiry that included an arbitration agreement and consent to marketing communications
• Outcome: Motion to compel arbitration denied without prejudice; motions to dismiss set aside while the parties conduct targeted discovery on contract formation

A federal court in Michigan has paused the merits of a Telephone Consumer Protection Act (TCPA) lawsuit against Rocket Mortgage while the parties resolve a threshold question: whether the plaintiff, or someone acting on his behalf, submitted an online mortgage inquiry containing his phone number.

In Dobronski v. Rocket Mortgage, LLC, the court denied Rocket Mortgage’s motion to compel arbitration without prejudice and ordered targeted discovery followed by a summary trial on the formation of the arbitration agreement.

Plaintiff Challenges Calls and Text Messages

Mark Dobronski alleged that he received 20 calls from the same telephone number between August 11 and August 19, 2025. According to his allegations, each call rang once and disconnected before he could answer.

Dobronski called the number back and reached an interactive voice response system identifying Rocket Mortgage. He eventually spoke with an agent who allegedly told him Rocket had been trying to contact him about refinancing.

Dobronski said he informed the agent that his number was on the Do Not Call Registry, that he was not interested, and that the calls should stop. He alleged that another call arrived in September, followed by a text message from a Rocket loan officer.

Rocket Points to Online Mortgage Inquiry

Rocket presented records showing that, on or around August 11, 2025, a user at a specific IP address visited a Rocket website and submitted a mortgage inquiry.

According to a declaration from a Rocket principal data analyst, the submission used the name “Testq Testing,” listed Dobronski’s telephone number and Michigan as the property state, and identified a purchase loan with a $250,000 loan amount.

The user then selected “Confirm & continue.”

Rocket maintained that a disclosure above the button informed users that proceeding constituted agreement to its Terms of Use. Those terms included an agreement to arbitrate TCPA-related claims and consent to receive marketing calls and texts, including when the telephone number appeared on a do-not-call list.

Rocket also submitted evidence of a second inquiry dated September 29, 2025, using the same name, phone number, and state but originating from a different IP address. Its analyst stated that company systems linked both submissions to the same individual.

Dobronski Denies Making the Submission

Dobronski responded with a sworn declaration denying that he or anyone acting on his behalf submitted the inquiry.

He also denied using the name “Testq Testing” or the IP address associated with the August submission. According to his declaration, publicly available IP lookup information connected that address to a Comcast connection at the Humane Society in Ann Arbor. He stated that he did not live in Ann Arbor and did not use Comcast.

Court Says Arbitration Question Must Come First

U.S. District Judge F. Kay Behm agreed that the formation question required further proceedings but rejected the approach of addressing the merits at the same time.

The court relied on Section 4 of the Federal Arbitration Act, which requires courts to address whether an arbitration agreement was formed when its existence is genuinely disputed.

Citing Sixth Circuit precedent, including Southard v. Newcomb Oil Co. and Boykin v. Family Dollar Stores of Michigan, LLC, the court determined that the arbitration issue must be resolved before the parties proceed with the merits of the TCPA claims.

As a result, Rocket’s motion to compel arbitration was denied without prejudice. Its first motion to dismiss was denied as moot, while its second motion to dismiss was denied without prejudice. The remaining objections were also overruled without prejudice.

The case will now proceed through targeted discovery and a summary trial focused on whether Dobronski, or someone acting for him, submitted the online form.

Arbitration Agreement Itself is not Challenged

The dispute is focused on whether an agreement was formed, rather than whether the arbitration provision would otherwise be enforceable.

According to the decision, Dobronski did not challenge the enforceability or scope of the arbitration agreement if the evidence ultimately establishes that he or an authorized agent submitted the inquiry.

That distinction makes the identity behind the online submission central to what happens next.

The court also declined to address Dobronski’s arguments concerning the scope of discovery at this stage, directing the parties to confer in good faith over discovery issues.

What the Decision Means

The ruling highlights the importance of establishing a reliable connection between an online lead submission and the individual whose contact information appears on the form.

For businesses relying on digital consent records, disputes over who actually completed an online form can become central to both TCPA consent and arbitration questions.

For now, the underlying TCPA claims remain on hold. The next phase will focus specifically on whether Dobronski or someone acting on his behalf made the online submission. The answer will determine whether Rocket can renew its effort to send the dispute to arbitration.