Troutman Pepper Locke State Attorneys General Monitor – May 1, 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

Solicitors General Insights: A Deep Dive With Mississippi and Tennessee Solicitors General

By Stephen C. Piepgrass and Jeff Johnson

In this episode of our special Regulatory Oversight: Solicitors General Insights series, Jeff Johnson, a former deputy solicitor general in the Missouri Attorney General’s office, welcomes Scott Stewart, solicitor general of Mississippi, and Matt Rice, solicitor general of Tennessee. The episode uncovers the intricacies of being a state solicitor general and the impact of their work on state and national levels.

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Multistate AG Updates

$51.75M Settlement in Clearview AI Biometric Privacy Litigation Illustrates Creative Resolution for Startups Facing Parallel Litigation and Enforcement Action

By Troutman Pepper Locke State Attorneys General Team, Dave Navetta, Lauren Geiser, Dan Waltz, and Nick Gouverneur

On Thursday, March 20, a federal judge in the Northern District of Illinois granted final approval to a settlement agreement under which Clearview AI (Clearview) agreed to pay an estimated $51.75 million to a nationwide class if one of several contingencies takes place. This approved settlement agreement resolves In Re: Clearview AI, Inc. Consumer Privacy Litigation, No. 1:21-cv-00135 (N.D. Ill.), a multidistrict suit alleging that the company’s automatic collection, storage, and use of biometric data violated various privacy laws, including Illinois’ Biometric Information Privacy Act (BIPA). The unorthodox settlement not only preserves Clearview’s business model, but may also insulate Clearview from subsequent or parallel regulatory investigations without requiring the company to jeopardize the liquidity necessary for continued growth. Ultimately, this settlement seems to represent a good outcome for the company, especially in light of the fact that that it was achieved over the objections from 23 state attorneys general (AG). U.S. District Judge Sharon Johnson Coleman stated that the settlement is fair, reasonable, and adequate.

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Single State AG Updates

Rhode Island AG Targets Real Estate Management and Development Firm for Alleged Unfair and Deceptive Acts and Practices

By Troutman Pepper Locke State Attorneys General Team and Blake Christopher

In mid-April, Rhode Island Attorney General (AG) Peter F. Neronha announced a settlement with A.R. Building Company, Inc. (ARBC), a national real estate management and development business with properties throughout Rhode Island. The settlement resolved allegations of unfair trade practices with respect to prospective tenants.

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Indiana AG Pushes Back on THC Legislation

By Jean Smith-Gonnell, Chris Carlson, and Nick Ramos

On April 21, Indiana Attorney General (AG) Todd Rokita issued a letter to state legislators addressing the pressing issue of legal loopholes surrounding intoxicating hemp-derived products containing delta-8 THC, delta-10 THC, or HHC. These products have garnered significant attention due to their psychoactive effects similar to Delta-9 THC, the primary compound in marijuana. In 2023, Rokita issued an official opinion concluding that these types of products are currently illegal in Indiana. Rokita’s letter discusses the proposed Senate Bill 478, which, among other things, seeks to regulate craft hemp, craft hemp flower products, and THC. Rokita concluded that the proposed bill would make these products legal, does not meaningfully regulate them, and encourages the legislature to reconsider the legislation.

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AG of the Week

Kwame Raoul, Illinois

Kwame Raoul was sworn in as Illinois’ 42nd attorney general (AG) in 2019 and took the oath for a second term on January 9, 2023.

Raoul began his legal career as a Cook County prosecutor and later became a partner at two national corporate law firms. He also served as an Illinois state senator for 14 years, which he describes as his “dream job.”

Raoul has championed legislation to counter the long-term effects of violent crime and to support survivors. He established the first-of-its-kind task force to dismantle Organized Retail Crime networks and leads the Illinois Internet Crimes Against Children Taskforce to protect children from online predators.

Raoul collaborates with federal law enforcement to prevent mass shootings in schools and places of worship, combat violent crime, and investigate fraud and public corruption. He spearheaded a partnership with state and local law enforcement enhance professionalism, accountability, and transparency among law enforcement officers statewide.

Raoul also protects Illinois consumers. The office handles tens of thousands of consumer fraud complaints annually, saving residents millions through litigation and mediation each year. He holds industries that jeopardize public health with opioids, e-cigarettes, and environmental pollution accountable. Raoul continues to fight against scams related to home repairs, auto sales, mortgages, identity theft, and student lending.

Raoul frequently coordinates with other state AGs to advocate for access to quality health care and reproductive health services, protect natural resources, promoted just immigration policies, reduce gun violence, and uphold civil rights for all individuals.

Illinois AG in the News:

• On April 29, Raoul, as part of a multistate coalition of 25 states and AGs, filed a lawsuit challenging the dismantling of AmeriCorps.

• On April 29, Raoul led a coalition of 14 AGs in sending a letter to Congress, urging members to oppose two Congressional bills that would prohibit the U.S. Environmental Protection Agency (EPA) from relying on scientific assessments from the Integrated Risk Information System (IRIS) program.

• On April 25, Raoul released a consumer alert urging student borrowers to get out of default and be wary of scammers.

Upcoming AG Events

• May: RAGA | ERC Retreat | Oahu, HI

• May: DAGA | Williamsburg Policy Conference | Williamsburg, VA

• June: RAGA | Summer National Meeting | New York, NY

For more on upcoming AG Events, click here.

Our Cannabis Practice provides advice on issues related to applicable federal and state law. Marijuana remains an illegal controlled substance under federal law.