Troutman Pepper Locke State Attorneys General Monitor – February 21, 2025

State attorneys general increasingly impact businesses in all industries. Our nationally recognized state AG team has been trusted by clients for more than 20 years to navigate their most complicated state AG investigations and enforcement actions.

State Attorneys General Monitor analyzes regulatory actions by state AGs and other state administrative agencies throughout the nation. Contributors to this newsletter and related blog include attorneys experienced in regulatory enforcement, litigation, and compliance. Also visit our State Attorneys General Monitor microsite.

Contact our State AG Team at StateAG@troutman.com.

Troutman Pepper Locke Spotlight

State Regulators Step Up: Responding to the CFPB’s New Leadership

By James Kim, Stephen Piepgrass, Chris Willis, Jesse Silverman, and Lane Page

In this special joint edition of the Consumer Finance Podcast and the Regulatory Oversight Podcast, host Chris Willis is joined by colleagues Stephen Piepgrass, James Kim, Jesse Silverman, and Lane Page to discuss the ongoing changes at the Consumer Financial Protection Bureau (CFPB) and predict how state regulators and legislatures will react to fill the void. This episode explores the anticipated responses from state attorneys general, financial service regulators, and legislatures, and offers strategic insights for industry players to navigate this complex regulatory environment. Tune in to understand the proactive measures your organization can take to stay compliant and ahead of potential state enforcement actions.

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State AG Updates

Vermont AG Clark Secures $2.7M Judgment Against Mental Health Counselor

By Troutman Pepper Locke State Attorneys General Team

On February 4, a Vermont Superior Court judge entered a $2,733,989.47 judgment against Phoenix Counseling & Wellness, PLC (Phoenix), and the company’s owner for alleged violations of the Vermont False Claims Act (VFCA). Vermont Attorney General (AG) Charity Clark and her office’s Medicaid Fraud and Residential Abuse Unit (MFRAU) received complaints regarding the quality of care and maintenance of patient treatment records by Phoenix.

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DOJ and 18 States Reach False Claims Act Settlement with QOL

By Troutman Pepper Locke State Attorneys General Team, Michael S. Lowe, and Amy Pritchard Williams

The U.S. Department of Justice (DOJ) and 18 state attorneys general (AG) announced a settlement with Boston-based QOL Medical, LLC (QOL) and its CEO, Frederick Cooper, to resolve allegations that the company provided unlawful kickbacks to health care providers. Under the terms of the settlement, QOL and Cooper agreed to pay $47 million to resolve allegations that QOL manipulated health care providers into prescribing a drug called Sucraid — an FDA-approved therapy for a rare genetic disorder, Congenital Sucrase-Isomaltase Deficiency (CSID). Regulators alleged that QOL and Cooper violated the Anti-Kickback Statute and federal and state False Claims Acts.

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AG of the Week

Dave Sunday, Pennsylvania

Dave Sunday was elected as Pennsylvania’s attorney general (AG) in November 2024, taking office in January 2025. Before running for AG, Sunday served as a prosecutor with the York County District Attorney’s office. Prior to being sworn in as the elected district attorney, he held the position of chief deputy prosecutor of litigation. In that capacity, Sunday supervised major crime cases and the felony narcotics unit. Additionally, he served as the legal advisor to the district attorney’s Drug Task Force and the York County Quick Response (SWAT) team.

Sunday is a career litigator and has personally tried approximately 50 felony jury trials to verdict, including the successful prosecutions of more than 10 of the most high-profile York County murders in recent memory. In 2013, Sunday was appointed as a special assistant U.S. attorney for the Middle District of Pennsylvania, where he assisted in prosecuting gang, illegal gun, and drug cases. During this time, he led the prosecution of Operation Sunrise, a large-scale multijurisdictional arrest and prosecution of more than 100 members and affiliates of the “Latin Kings,” a violent criminal gang operating in York County.

Beyond trial work, Sunday is the immediate past president of the York County Bar Association and serves on the board of the York County Children’s Advocacy Center. He also chairs the Education and Training Committee of the Pennsylvania District Attorney’s Association (PDAA) and was elected by his colleagues to the board of directors for the PDAA and the Pennsylvania District Attorney’s Institute. Nationally, Sunday serves on the American Conservative Union’s prosecutor advisory board and has spoken across the U.S. on effective public safety initiatives.

After high school, Sunday joined the Navy as an enlisted recruit and was deployed to the Persian Gulf, where he participated in Operation Desert Strike. He was also deployed to South America and conducted numerous counter-narcotics operations in the Caribbean. He then received his undergraduate degree in finance from Penn State University in 2002 and graduated from Widener Law School in 2007.

Pennsylvania AG in the News:

• On February 13, Sunday joined a multistate coalition in a letter to the U.S. Senate asking for passage of the HALT Fentanyl Act.
• On February 11, Sunday issued an advisory warning Pennsylvanians about a trending cyber scam.

Upcoming AG Events

• March: AGA | Women’s Empowerment Summit | Del Mar, CA
• March: RAGA | Spring Golf Retreat | Pinehurst, NC
• April: NAAG | AG Symposium | Nashville, TN

For more on upcoming AG Events, click here.