Troutman Pepper Locke State Attorneys General Team

On February 9, Connecticut Attorney General (AG) William Tong announced an investigation into the owners and managers of the Concierge Apartments in Rocky Hill, CT, for potential violations of the Connecticut Unfair Trade Practices Act after frozen pipes burst and tenants were displaced.

Recent opinions by the Texas attorney general (AG) and the Florida AG assert that their states’ race- and sex-conscious laws and policies are unconstitutional. The opinions align with President Donald Trump’s 2025 Executive Orders 14151 and 14173 (collectively, the executive orders), which seek to end gender- and race-based contracting practices and dismantle diversity, equity, and inclusion (DEI) initiatives. Like the executive orders, the AG opinions target DEI-related policies affecting state contracting, appointments, and employment; the Texas AG also specifically asserts that private employers’ applicable DEI policies (as described within the opinion) violate Texas and federal law, thereby targeting both the private and public sectors.  Although not legally binding on courts, such opinions provide a guide for the likely contours of future enforcement action by these state attorneys general.

California Attorney General (AG) Rob Bonta recently announced a consent judgment resolving allegations that the Pacific American Fish Company, Inc. (PAFCO), a seafood distributor and processor, had sold frozen seafood products with elevated levels of lead and cadmium in California without the warnings required by state law.

What Happened

On January 16, Attorney General (AG) Jason Miyares’s last day in office, the Virginia AG reached a settlement with Viatris, Mylan’s corporate successor, over EpiPen pricing and related practices. The settlement was filed and approved by the Circuit Court for the City of Richmond without issuance of a press release by the Virginia AG.

Arizona Attorney General (AG) Kris Mayes recently announced a consent judgment with SimonMed Imaging MSO, LLC (SimonMed), alleging that the medical imaging service provider violated the Arizona Consumer Fraud Act through billing practices the AG claimed were unfair and misleading. SimonMed provides management services, including billing, collections, information technology, and other business administrative services, to SMI Imaging, LLC (SMI), a wholly owned subsidiary of SimonMed Imaging LLC. According to its website, SimonMed Imaging LLC is the largest outpatient physician radiology group in the U.S., and its subsidiary SMI is the provider entity in connection with outpatient imaging clinics in Arizona. SimonMed expressly denies any liability or wrongdoing, and the consent judgment is not to be construed as an admission of wrongdoing or a violation of the law.

In a pair of recent submissions to the Federal Communications Commission (FCC), a bipartisan coalition including more than 20 state attorneys general (AG) opposed action by the FCC to preempt state and local laws relating to artificial intelligence (AI). The coalition’s comments reflect persistent concerns among AGs about how businesses use AI when interacting with their residents, even as some federal policymakers support limiting states’ ability to address those concerns.

On his last day in office, New Jersey Attorney General (AG) Matt Platkin announced a consent order resolving a consumer fraud investigation into Skims Body, Inc. for charging consumers in New Jersey sales tax on items that are exempt under state law. Founded by Kim Kardashian, Skims is primarily an online retailer of apparel. The company agreed to pay $200,000 in civil penalties and to comply with the consent order’s injunctive terms.    

On January 5, 2026, Colorado Attorney General (AG) Phil Weiser announced that MC Global Holdings and affiliated persons and entities (collectively, MC) had been fined for allegedly violating the terms of a May 2025 assurance of discontinuance. The defendants, who are engaged in manufacturing, packaging, labeling, distributing, and/or selling industrial hemp products under the brand Vivimu, agreed to a fine of $575,000, of which $500,000 will be suspended as long as they comply with the terms of the new agreement.

State attorneys general (AGs) are among the most active and influential regulators in the U.S., using broad statutory authority, political visibility, and growing technical knowledge to shape policy and enforcement across sectors. In 2025, they asserted their authority to shape the legal and regulatory environment across the U.S. through aggressive and coordinated action. Despite changing