Articles + Publications October 22, 2026

Troutman Pepper Locke State Attorneys General Monitor – October 22, 2026

State attorneys general (AGs) 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.

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


In the Spotlight

A Look Ahead to the 2026 State AG Elections From DAGA President Sean Rankin

By Ashley L. Taylor, Jr. and Clayton Friedman

In this episode of Regulatory Oversight, Ashley Taylor and Clayton Friedman, co-leaders of Troutman Pepper Locke’s State AG team, welcome Democratic Attorneys General Association (DAGA) President Sean Rankin for a wide-ranging look at the 2026 state AG elections and a landscape he says has shifted significantly over the course of the cycle.

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Multistate Updates

A Permanent Injunction Isn’t the End: State AGs Are Policing Compliance With Court Orders Through Separate Contempt Actions

By Troutman Pepper Locke State Attorneys General Team

A final court order does not necessarily mean an end to the involvement of state AGs in an enforcement action. As a recent filing shows, state AGs are now treating failure to comply with post-judgment permanent injunctions as standalone contempt actions.

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Eight State AGs Sue OpenAI Over ChatGPT Safety and Consumer Protection

By Ashley L. Taylor, Jr., Clayton Friedman, Chris Carlson, Chanel Thomas, Alexandra Lancey, Matthew Berns, and William LaRosa

Eight state AGs filed separate but coordinated lawsuits against OpenAI on October 14, alleging that the company misled consumers about ChatGPT’s safety and failed to adequately protect children and other users from harmful interactions.

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Single State Updates

Vermont AG Secures $60,000 Settlement With UniFirst Over Auto-Renewal Allegations

By Troutman Pepper Locke State Attorneys General Team

On October 14, 2026, Vermont AG Charity Clark announced a settlement with UniFirst based on allegations that the company did not comply with Vermont’s auto-renewal law.

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Massachusetts’ Price Disclosure Rules Raise the Bar: Class Action and AG Enforcement Risks in a Post-Click-to-Cancel World

By David Fialkow and Michael Lafleur

The national conversation about so-called junk fees — charges hidden until the final stage of a consumer transaction — has accelerated dramatically over the past three years. Federal regulatory efforts have stalled or been struck down. Most notably, on July 8, 2025, just days before a scheduled compliance deadline, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) sweeping amendment to its Negative Option Rule on procedural grounds.

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AG of the Week

Marty Jackley, South Dakota

Marty Jackley was raised in Sturgis and graduated from the South Dakota School of Mines with a bachelor’s degree in electrical engineering, with honors. After receiving his law degree from the University of South Dakota, he served as a clerk for then-Chief Federal Judge Richard Battey. Jackley then entered private practice and also served as a special assistant AG prosecuting controlled substance felonies.

In 2006, Jackley was appointed and unanimously confirmed by the U.S. Senate as the U.S. attorney for South Dakota.

From 2009 to 2019, Jackley served as South Dakota’s AG. In 2015, he served as president of the National Association of Attorneys General (NAAG), and he also chaired the Conference of Western Attorneys General (CWAG). In 2016, he received the National AG of the Year award from his fellow AGs. After serving 10 years as AG, Jackley returned to private practice as a senior partner. He also served as state’s attorney for both Jones and Haakon counties, and as a special prosecutor for the Sisseton Wahpeton Oyate during this time. In 2022, Jackley was elected to return as South Dakota AG. He served as chairman of the Attorneys General Alliance (AGA) from 2023 to 2024. Jackley was elected president-elect of NAAG in December 2025. In June 2026, he won the Republican nomination for South Dakota’s at-large seat in the U.S. House of Representatives rather than seeking another term as AG.

AG in the News
  • Jackley has joined a bipartisan group of AGs in filing a notice in Character Technologies, Inc.’s (Character.AI) bankruptcy case, raising safety and privacy concerns, and urging that children and consumers be protected in any sale of the company’s business or assets.  
  • Jackley and 45 other states and territories are seeking court approval of settlements with generic drugmakers Ascend Laboratories, Mayne Pharma, and Citron Pharma over alleged price-fixing, with each company agreeing to internal antitrust reforms; South Dakota receiving small payments from Ascend and Mayne; and the states preparing for a first trial in Hartford, CT, in February 2027.

Upcoming AG Events

  • October: AGA | Working Group Meetings | Denver, CO
  • October: NAAG | Fall Consumer Protection | Washington, DC
  • November: RAGA | Fall National Meeting | Dallas, TX
  • November: DAGA | Policy Conference | Chicago, IL
  • November: AGA | International Delegation | Australia

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 ancillary regulatory issues. Our successful approach has been recognized by Chambers USA, which ranked our practice as a leader in the industry.