Analysis · Do Not Call
FTC v. Grand Canyon University: Telemarketing Claims Filed, Then Dismissed
The Federal Trade Commission (FTC) sued Grand Canyon Education, Inc. (GCE), Grand Canyon University (GCU) and Brian Mueller, CEO of GCE and president of GCU, in federal court in Arizona. The FTC alleged deceptive advertising and illegal telemarketing. On August 15, 2025, the FTC announced it had voted to dismiss the case.
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The bottom line: the case ended without any finding against the defendants, but the complaint shows how the FTC applies the Telemarketing Sales Rule (TSR) to education marketing.
What the FTC alleged
The original complaint was filed December 27, 2023. An unsealed and unredacted version was filed January 29, 2024, in Case No. 2:23-cv-02711 (D. Ariz.). An amended complaint followed on September 30, 2024. Read the FTC complaint against Grand Canyon University.
According to the FTC, the defendants deceived prospective doctoral students about the cost and course requirements of doctoral programs and about GCU being a nonprofit.
On telemarketing, the complaint alleges:
- Since July 2018, GCE initiated tens of millions of telemarketing calls on behalf of GCU.
- The marketing resulted in millions of abusive telemarketing calls to consumers who had asked not to be solicited, and to people on the National Do Not Call Registry.
- GCE has hundreds of sales representatives, and its telemarketers tell prospective students they are GCU counselors.
- Telemarketers who missed performance metrics were placed on "Corrective Action Plans" that routinely required 80 to 89 calls a day.
On the nonprofit claims, the complaint states that the Department of Education, on November 6, 2019, rejected GCU's request to be recognized as a nonprofit under the Higher Education Act. GCU has sought a court declaration that it may call itself a nonprofit.
How the case ended
On August 15, 2025, the parties filed a stipulation of dismissal with prejudice. Chairman Andrew N. Ferguson, joined by Commissioners Melissa Holyoak and Mark R. Meador, issued a statement on the decision.
A dismissal with prejudice means the FTC cannot refile these claims. The allegations were never proven in court.
The law
The TSR prohibits calling consumers who have asked a seller not to call them (the entity-specific do-not-call list) and calling numbers on the National Do Not Call Registry without an applicable exception. These rules apply to educational services sold by phone.
Why it matters
Call quotas are common in sales. The FTC's complaint treated high daily call requirements, combined with weak do-not-call controls, as a source of violations. Organizations that market by phone, including schools, should make sure volume targets do not override suppression lists.
What this means for you
- Maintain and honor an internal do-not-call list.
- Scrub against the National Do Not Call Registry.
- Make sure call quotas do not push staff to call suppressed numbers.
- Be accurate when your representatives describe who they work for.
Not legal advice. TCPA.com provides general information, not legal advice, and is not a substitute for the advice of an attorney. Do not rely on it. Verify any action with your own licensed lawyer before you take it. See our Terms of Use.
Primary sources
About the Author: Harrison Gevirtz
Harrison Gevirtz serves as the Chief Strategy Officer (CSO) of Ringba, a call tracking and pay per call platform, and is based in Las Vegas, Nevada. Harrison Gevirtz is a serial operator in call tracking, call routing and telemarketing operations, and for the past several years he has focused on how federal regulations affect the daily operations of these industries. At TCPA.com, Harrison Gevirtz covers TCPA litigation, Telemarketing Sales Rule (TSR) enforcement, tech support fraud prosecutions and Federal Communications Commission (FCC) rulemaking in a way that's accessible to the non-lawyer executive or compliance manager.
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