On July 14, 2023, the U.S. Court of Appeals for the Third Circuit issued a precedential decision that expands the scope of the type of "need" a carrier can use to challenge a land use denial under the Federal Telecommunications Act (TCA). In Cellco Partnership v. White Deer Township Zoning Hearing Board, Docket No. 22-2392 (3d Cir. 2023), the court affirmatively adopted the Federal Communications Commission's (FCC) "material inhibit" standard for violations of the TCA and replaced the existing "effective prohibition standard." As will be discussed in this article, this standard is a lower threshold that can be met not only with respect to the filling of significant gaps in a carrier's coverage, but also when a carrier is densifying a wireless network, introducing new services or otherwise improving service capabilities. The new standard of review also contemplates the totality of inhibiting factors, including costs, and not just those created by a municipal zoning ordinance. This is a sea change in the standard of review that will apply to local decisions impacting wireless services in New Jersey.