Kramer Lawsuit Over AI Biden Election Robocalls

The federal civil lawsuit over Steve Kramer’s AI-generated Biden robocalls ended on November 20, 2025, when a judge in the U.S. District Court for the District of New Hampshire entered a default judgment against Kramer, awarding $22,500 in damages to three New Hampshire voters and imposing a nationwide permanent injunction on his future conduct.¹ The three corporate co-defendants settled separately, and a related FCC enforcement action produced a $6 million fine against Kramer that he has said he will not pay.

What the Robocalls Did

On January 21, 2024, two days before the New Hampshire presidential primary, roughly 9,581 robocalls went out to New Hampshire voters using a spoofed 603 area code caller ID.² An AI-generated voice made to sound like President Biden told recipients to “save your vote for the November election” and that “your vote makes a difference in November, not this Tuesday,” suggesting that voting in the primary would somehow spoil their general-election ballot.³

Kramer, a New Orleans-based Democratic political consultant, hired Louisiana magician Paul Carpenter to generate the voice clone for $150. The calling list contained about 5,000 registered Democrats who had voted in the 2020 primary. The calls originated with Life Corporation, a Texas robocalling firm owned by Walter Monk, and were transmitted by Lingo Telecom.² Kramer was under a six-figure contract with the presidential campaign of Rep. Dean Phillips at the time, but the campaign said the contract covered only ballot access work in New York and Pennsylvania and publicly denounced the robocalls.⁴

Who Sued and Under What Laws

The League of Women Voters of New Hampshire and three individual voters — James Fieseher, Nancy Marashio, and Patricia Gingrich — filed League of Women Voters of New Hampshire v. Kramer on March 14, 2024, in the U.S. District Court for the District of New Hampshire.⁵ The complaint named Kramer along with three corporate defendants: Lingo Telecom, Life Corporation, and Voice Broadcasting Corporation (a second Monk-owned company).

The plaintiffs alleged voter intimidation under Section 11(b) of the Voting Rights Act of 1965, violations of the Telephone Consumer Protection Act, and violations of two New Hampshire statutes governing political advertising.⁶ They sought statutory and punitive damages, attorney’s fees, and a nationwide injunction covering AI-generated impersonations and spoofed communications. In July 2024, the U.S. Department of Justice filed a statement of interest backing the plaintiffs’ right to bring a private action under the Voting Rights Act.⁷

The Default Judgment Against Kramer

Kramer never appeared or defended the case. The court entered a default against him on August 29, 2024.⁸ On November 20, 2025, Judge Steven J. McAuliffe ruled for the plaintiffs on all four counts of the amended complaint and awarded $7,500 to each of the three individual voters — $22,500 total — reflecting trebled damages for willful violations of the TCPA and New Hampshire election laws.¹

The nationwide permanent injunction bars Kramer from:

Orchestrating deceptive robocall campaigns that intimidate voters;
Commissioning AI deepfake recordings for election-related calls without consent;
Transmitting misleading caller ID information for election calls; and
Delivering prerecorded political messages without disclosing the sender within the first 30 seconds.¹

Kramer told reporters he would not pay the damages, called the lawsuit a “publicity stunt,” and pointed to his acquittal in the parallel state criminal case.⁹

How the Telecom Defendants Resolved Their Cases

The three corporate defendants settled without going to judgment. In March 2025, the parties jointly stipulated to dismiss Lingo Telecom, which had already entered a consent decree with the FCC in August 2024.⁵

In May 2025, the court approved a consent judgment with Life Corporation and Voice Broadcasting Corporation. The two companies acknowledged that their robocalls “had the potential to intimidate voters in violation of the Voting Rights Act” and agreed to a compliance program that includes a dedicated compliance team, mandatory staff training on deceptive messages and election misinformation, and stricter reporting around spoofed calls.¹⁰ With the corporate defendants resolved and the default entered against Kramer, the case concluded in November 2025.¹¹

The Criminal Acquittal Did Not Disturb the Civil Judgment

Separately, the New Hampshire Attorney General’s office indicted Kramer on May 23, 2024, on 13 felony voter suppression counts and 13 misdemeanor counts of impersonating a candidate, based on 13 identified voters across four counties.³ Each felony carried up to seven years in prison, each misdemeanor up to one year.¹² The counts were consolidated to 11 and 11 by trial.

At trial in Belknap County Superior Court, Kramer testified that his goal was to “send a wake-up call” about unregulated AI in politics, calling the effort his “one good deed this year.” His lawyers argued that the state’s voter suppression statute did not apply because the Democratic National Committee had not sanctioned New Hampshire’s primary, and that no impersonation occurred because the recording never named Biden and Biden was not on the state’s ballot.¹³ On June 13, 2025, the jury acquitted him on all 22 counts.¹⁴

The acquittal had no effect on the federal civil case. The default judgment had already been entered, and civil liability under the Voting Rights Act and TCPA rests on a lower standard of proof than a criminal conviction.

The FCC Fines Are Separate From the Lawsuit

Two FCC enforcement actions ran in parallel to the civil suit. In May 2024, the commission proposed a $6 million fine against Kramer for violating the Truth in Caller ID Act.¹⁵ The forfeiture order was finalized on September 26, 2024, and Kramer has said he will not pay.¹⁶

Lingo Telecom faced a proposed $2 million fine but settled in August 2024 for $1 million under a consent decree that required stronger anti-spoofing procedures, a senior manager with STIR/SHAKEN caller authentication expertise, a formal compliance plan, and 15-day reporting of any future non-compliance.¹⁷

The FCC also closed a regulatory gap the incident exposed. In February 2024, the commission unanimously adopted a declaratory ruling classifying AI-generated voices as “artificial” under the Telephone Consumer Protection Act, making their use in robocalls illegal without prior consent.¹⁸ That ruling supplied part of the legal footing on which the civil plaintiffs later prevailed.

1
League of Women Voters. Default Judgment and Report and Recommendation, LWVNH v. Kramer
2
FCC. Notice of Apparent Liability for Forfeiture, Steve Kramer
3
New Hampshire Department of Justice. Steven Kramer Charged With Voter Suppression Over AI-Generated President Biden Robocalls
4
PBS NewsHour. Magician Says Political Consultant Hired Him to Create AI Biden Robocall
5
League of Women Voters. League of Women Voters of New Hampshire v. Kramer
6
Justia. League of Women Voters of New Hampshire v. Kramer, No. 1:2024cv00073
7
U.S. Department of Justice. League of Women Voters of New Hampshire v. Kramer
8
Free Speech for People. League of Women Voters of New Hampshire v. Kramer
9
The Hill. Biden AI Robocall Lawsuit
10
CyberScoop. Biden AI Robocall League of Women Voters Lawsuit, Life Corporation, Voice Broadcasting
11
Free Speech for People. League of Women Voters and Free Speech for People Applaud Judgment in New Hampshire Voter Intimidation Lawsuit
12
Courthouse News Service. New Hampshire Jury Acquits Consultant Behind AI Robocalls Mimicking Biden on All Charges
13
WBUR. Biden AI Robocall New Hampshire Steven Kramer Not Guilty
14
NHPR. Political Operative Behind Fake Biden Robocalls Found Not Guilty
15
NPR. FCC AI Deepfake Robocall Biden New Hampshire Political Operative
16
FCC. FCC Issues $6M Fine for NH Robocalls
17
CyberScoop. Telecom Behind AI-Powered Biden Robocall Agrees to $1 Million FCC Fine
18
FCC. FCC Makes AI-Generated Voices in Robocalls Illegal