Troutman Pepper Locke State Attorneys General Monitor – June 12, 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

Facial Recognition and Legal Boundaries: The Clearview AI Case Study

By Stephen C. Piepgrass, David Navetta, Lauren Geiser, and Daniel Waltz

In this episode of the Regulatory Oversight podcast, Stephen Piepgrass welcomes David Navetta, Lauren Geiser, and Dan Waltz to discuss the $51.75 million nationwide class settlement involving Clearview AI and its broader implications. The conversation focuses on Clearview AI’s facial recognition software, which has sparked controversy due to its use of publicly available images to generate biometric data.

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American Bar Association’s State and Local Government Law Section Webinar Series: State Attorneys General Enforcement Actions and Litigation: The Unwritten Rules

By Ashley L. Taylor, Jr. and Michael Yaghi

Join Troutman Pepper Locke attorneys Ashley Taylor and Michael Yaghi as they participate in a two-part webinar series hosted by the American Bar Association’s State and Local Government Law Section. This series is designed to highlight chapters from the recently published book, “Consumer Protection: Understanding Enforcement Actions Brought by State Attorneys General.“ The webinar series will explore the complexities and nuances surrounding enforcement actions brought by consumer protection staff in state attorneys general offices.

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State AG News

New AG on the Block: Wyoming Interim Attorney General Ryan Schelhaas

By Troutman Pepper Locke State Attorneys General Team

On May 27, Wyoming Governor Mark Gordon announced the appointment of Ryan Schelhaas as interim attorney general (AG). Schelhaas succeeds AG Bridget Hill, who will join the Wyoming Supreme Court as its newest justice. Governor Mark Gordon has indicated he plans to nominate Schelhaas as the permanent replacement, enabling him to serve the remainder of the term as the state’s attorney general.

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Streaming Under Scrutiny: Michigan AG Alleges Roku Violates COPPA and Other Privacy Laws

By Troutman Pepper Locke State Attorneys General Team, Gene Fishel, Laura Hamady, Esther Kye, and Kyara Rivera Rivera

On April 29, Michigan Attorney General (AG) Dana Nessel filed a lawsuit against Roku, Inc. (Roku), the smart TV and device provider and streaming service, alleging that Roku collects and monetizes personal data from children without proper parental consent in violation of the Children’s Online Privacy Protection Act (COPPA) and other laws, including the Video Privacy Protection Act (VPPA) and the Michigan Consumer Protection Act.

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Texas Legislature Passes Comprehensive AI Governance Act

By Stephen C. Piepgrass, Gene Fishel, Laura Hamady, and Daniel Waltz

On June 2, the Texas legislature passed the Texas Responsible Artificial Intelligence Governance Act, (TX AI Act or bill) which heads to the governor for his signature or veto. The bill will take effect January 1, 2026, if the governor signs it into law. It is the most comprehensive piece of AI governance legislation to pass a state legislature to date. If enacted, Texas will become the fourth state after Colorado, Utah, and California to pass AI-specific legislation.

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NY AG Reaches $3.2M in Settlements With 8 New York Nissan Dealerships

By Troutman Pepper Locke State Attorneys General Team and Michael Lafleur 

New York Attorney General (AG) Letitia James’ office has reached a cumulative total of $3.2 million in settlements with eight Nissan dealerships that the office accuses of overcharging New Yorkers for purchasing leased vehicles at the conclusion of their lease term.

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Colorado Cracks Down on Hemp Misrepresentation

By Jean Smith-Gonnell and McKayla Riter

On May 14, Colorado Attorney General (AG) Phil Weiser announced that the state reached a settlement with MC Global Holdings, LLC, its associated companies, and owners (collectively MC) to resolve allegations that MC’s business practices violated the Colorado Consumer Protection Act (CCPA).

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AG of the Week

Peter F. Neronha, Rhode Island

Peter Neronha was elected as Rhode Island’s 74th attorney general (AG) on November 6, 2018, and sworn in on January 1, 2019. As the top legal officer in Rhode Island, Neronha leads an office that prosecutes criminal cases, represents state agencies, and initiates legal action to protect Rhode Islanders’ interests.

Appointed by President Barack Obama, Neronha served as the U.S. attorney for the District of Rhode Island from 2009 to 2017. In this role, he supervised the prosecution of federal crimes and the litigation involving the federal government. As U.S. attorney, he was appointed by U.S. Attorney General Eric Holder and later AG Loretta Lynch to terms on the AG’s Advisory Committee.

Neronha’s public service career began in 1996 as a Rhode Island special assistant AG, later becoming an assistant AG. He served in the Rhode Island AG’s office until 2002, prosecuting various criminal matters. Neronha joined the U.S. Attorney’s Office as an assistant U.S. attorney in 2002, serving in roles including chief of the Crime Strike Force.

A fourth generation native of Jamestown, RI, Neronha graduated summa cum laude from Boston College in 1985 and magna cum laude from Boston College Law School in 1989, where he was a member of the Boston College Law Review. From 1989 to 1996, he worked at the Boston law firm Goodwin, Proctor L.L.P.

Rhode Island AG in the News:

• On May 28, Neronha announced a series of sweeping actions to address what he called the state’s “failing health care system.”

• On May 21, Neronha announced an $11 million settlement with a construction company to resolve allegations of unlawful dumping of solid waste. The settlement money will be used to fund dental care services for Providence city youth.

Upcoming AG Events

• June: AGA | 2025 Annual Meeting | U.S. Virgin Islands

• July: RAGA | Victory Fund Golf Retreat | Pebble Beach, CA

• July: DAGA | Presidential Partners Retreat | Santa Fe, NM

For more on upcoming AG Events, click here.

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