Troutman Pepper Locke State Attorneys General Monitor – October 23, 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

Compliance and Enforcement in Consumer Financial Services: Navigating the Changing Landscape of Federal and State Oversight

By Troutman Pepper Locke State Attorneys General Team

Register Here

Wednesday, October 29 | 1:00 – 3:10 p.m. ET

Mike Yaghi and Lane Page, members of Troutman Pepper Locke’s State Attorneys General practice, along with Stefanie Jackman and Caleb Rosenberg from the Consumer Financial Services practice, will participate in an upcoming CLE webinar with myLawCLE. They will analyze the evolving roles and enforcement priorities of federal and state regulatory agencies, focusing on their impact on consumer financial services.

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Multistate AG News

28 State AGs Defend State ENDS Directory Laws in Amicus Brief to Fourth Circuit

By Troutman Pepper Locke State Attorneys General Team, Bryan Haynes, and Michael Jordan

On September 22, a group of 28 state AGs led by Iowa filed an amicus brief in Vapor Technology Association v. Wooten in support of North Carolina’s state directory law that prohibits the sale of electronic nicotine delivery system (ENDS) products or e-cigarettes that lack Food and Drug Administration (FDA) marketing authorization. According to the brief, 15 states have already enacted laws similar to North Carolina’s ENDS directory law, and another 25 states are considering such legislation.

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Single State AG News

Illinois Department of Insurance Initiates Litigation Against State’s Largest Insurer Over Failure to Produce Document

By Troutman Pepper Locke State Attorneys General Team and Mary Grace Metcalfe

On October 10, 2025, Illinois Attorney General (AG) Kwame Raoul filed a lawsuit on behalf of Ann Gillespie, director of the Illinois Department of Insurance (the Department), against four different entities, all within the State Farm corporate umbrella. This lawsuit arises from State Farm’s alleged refusal to comply with financial examination warrants issued by Director Gillespie, which aim to force State Farm to disclose information about the policies it writes and the premiums it charges. As insurance regulation is a creature of state law, the Department’s director oversees the enforcement and execution of all insurance laws in Illinois. Further, AG Raoul has authority to bring lawsuits on behalf of other Illinois state agencies.

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Minnesota AG Ellison Reaches $800,000 Settlement With Shipt on Worker Classification

By Troutman Pepper Locke State Attorneys General Team

On September 26, 2025, Minnesota Attorney General (AG) Keith Ellison announced a $800,000 settlement with Shipt, Inc. (Shipt). The settlement resolves allegations that the company was misclassifying its workers (referred to as “Shoppers”) as independent contractors instead of employees.

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California Charts the Frontier With First Law Setting Reporting And Compliance Requirements For Powerful “Frontier AI Models”

By Troutman Pepper Locke State Attorneys General Team

On September 29, 2025, California Governor Gavin Newsom signed Senate Bill 53, the Transparency in Frontier Artificial Intelligence Act, into law. The bill will go into effect on January 1, 2026. The act builds upon the recommendations found in the “California Report on Frontier AI Policy,” which was released to the public on June 17, 2025. This report detailed key principles to guide the legislation drafting process, including grounding AI policy in empirical research and providing greater transparency into AI systems. Given that California is home to 32 of the top 50 AI companies worldwide, the state dominates the AI industry. It is no surprise that California is the first state to create rules promoting safety, transparency, and incident reporting for frontier models. This new act is expected to set the stage for similar AI legislation across the U.S.

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AG of the Week

J.B. McCuskey, West Virginia

J.B. McCuskey was elected as West Virginia’s attorney general (AG) in November 2024 and took office in January 2025. He earned his undergraduate degree in political communication from The George Washington University and a law degree from West Virginia University College of Law. Early in his career, McCuskey worked as a civilian in the general counsel offices of the Army and Department of Defense at the Pentagon.

McCuskey began his public service in the West Virginia House of Delegates, serving from 2013 to 2017, where he supported policies related to fiscal responsibility, job creation, and energy. He was elected West Virginia state auditor in 2016 and served two terms. As auditor, McCuskey implemented systems for public access to real-time government spending data and developed a platform to track government expenditures, fraud, and abuse. He also streamlined the property tax process and advocated for updates to longstanding tax laws.

Upcoming AG Events

• November: DAGA | Scottsdale Policy Conference | Scottsdale, AZ

• November: AGA | International Delegation

• December: DAGA | Holiday Party | Washington, D.C.

For more on upcoming AG Events, click here.

Troutman Pepper Locke’s State Attorneys General team combines legal acumen and government experience to develop comprehensive, thoughtful strategies for clients. Our attorneys handle individual and multistate AG investigations, proactive counseling and litigation, and manage ancillary regulatory issues. Our successful approach has been recognized by Chambers USA, which ranked our practice as a leader in the industry.