State Attorney General actions and investigations can hit hard—financially, reputationally, and operationally. At Steptoe, we know how to mitigate the risk. Our team brings sharp strategy, influential relationships, deep regulatory insight, and courtroom firepower to protect your business and reputation when it matters most.
State AGs wield broad enforcement authority—and they're using it more than ever. From consumer protection and financial services to antitrust, data privacy, environmental law, and labor practices, AGs are targeting businesses across industries. We level the playing field with:
- Sophisticated, business-specific defense strategies.
- Deep knowledge of state enforcement dynamics and many of the key players.
- A proven track record in high-stakes litigation and negotiation.
AG scrutiny rarely happens in isolation. One action can trigger a cascade—from federal agencies and the DOJ to local law enforcement and even Congress. And when one AG acts, others often follow. We understand the politics, the pressure, and the playbook—and we help you stay one step ahead.
Our Experience Runs Deep
We've successfully defended clients in complex, high-profile AG matters, including:
- Consumer Protection Claims. Allegations of deceptive practices, UDAP violations, and telemarketing issues.
- Financial Services Disputes. State-led inquiries into banking, fintech, and consumer finance.
- Antitrust Actions. Accusations of monopolistic behavior, price-fixing, and anti-competitive conduct.
- Data Privacy & Cybersecurity. Breach litigation and compliance issues under state laws.
- Environmental Litigation. Claims tied to contamination, climate, and regulatory failures.
- Fraud & Financial Misconduct. Defense against fraud, deceptive marketing, and financial wrongdoing claims.
- Public Nuisance Claims. Cutting-edge litigation involving pharmaceuticals, chemicals, and more.
How We Win
- Pre-Litigation Resolution. We often resolve matters before they escalate—negotiating directly with AG offices to secure favorable pre-litigation resolutions.
- Strategic Case Planning. We assess risk, map out defenses, and anticipate where the law is headed—not just where it stands today.
- Trial-Ready Advocacy. If it goes to court, we're ready. Our litigators are seasoned courtroom advocates, strategic, and relentless.
Representative Matters
State AG Litigation Experience By Industry Sector
Chemicals, Environment, and Life Sciences
- Defending a global energy company in a natural resource damages lawsuit filed by New Jersey Department of Environmental Protection and other government entities through the NJ Attorney General and a series of private law firms hired as special counsel to the Attorney General.
- Negotiated a favorable judgment with state AG resolving years-long Proposition 65 claim involving alleged presence of lead in manufacturer's baby and toddler formulas.
- Defending an avocado growing, packing, shipping, distribution company in a private attorney general action filed on behalf of District residents in District of Columbia Superior Court, alleging that the company's sustainability and environmental-friendliness representations violate the DC Consumer Protection Procedures Act.
- Negotiated global settlement with all 50 states and 6 US territories resolving investigation into pharmaceutical marketing practices, including related insurance issues.
- Defended public nuisance litigation brought by numerous State AGs relating to the use of lead pigment in paint.
- Defended generic pharmaceutical company in State AG public nuisance litigation.
- Defended Aquestive against a civil enforcement action brought by 40 states and the District of Columbia alleging antitrust violations, winning summary judgment with dismissal of all claims.
- Defending Molina Healthcare against the state of Texas in a matter alleging Medicaid fraud with alleged damages exceeding $500 million. A former employee of Molina filed a qui tam suit asserting violations of the Texas Medicaid Fraud Prevention Act (TMFPA).
- Represented a party in the Texas Opioid MDL in which the State AG was an intervenor.
Financial Services Litigation and Investigations
- Representing Citibank in a case brought by the New York Attorney General in the Southern District of New York challenging Citibank's handling of alleged fraudulent wire transfers initiated online.
- Successfully negotiated a settlement with the Massachusetts Attorney General’s Office, resolving an investigation pending for more than four years into a mortgage servicer's practices concerning pre-foreclosure property preservation and inspection services, title and valuation services, and services related to lender-placed insurance.
- Represented iFinex Inc., the owner of the Bitfinex cryptocurrency exchange, and Tether, the world's largest stablecoin issuer, in investigations by the CFTC and the New York Attorney General's Office; both investigations were resolved with settlements favorable to the company.
- Represent Synchrony Bank in its negotiated settlement with multiple California District Attorneys of Rosenthal Act claims based on allegedly excessive call volume.
- Handled a multiple state attorney general investigation for a regional bank.
- Represent bank owned payments platform in a NYAG investigation into its fraud prevention and detection practices.
- Represent fintech credit company in connection with license revocation proceedings involving the California DFPI.
- Represent major global financial institution in a fair lending investigation by the New York Human Rights Commission.
- Represent short-term, small dollar lender in an enforcement action involving the California DFPI.
- Represent two major credit unions in connection with an investigation by the Colorado Attorney General into their practices concerning refunds of GAP waiver fees upon consumer prepayment of auto loans.
- Represent an earned wage access provider in connection with a multi-state investigation (14 states), led by California and New York, into its business practices.
- Represent a prepaid card provider in connection with multi-state enforcement actions concerning certain prior unlicensed conduct.
- Represent a global bank in California Attorney General investigation concerning alleged mortgage fraud.
- Represent major non-bank mortgage servicer in connection with investigation by the Ohio Attorney General.
- Represent a foreign bank in connection with an AML/BSA investigation by the NYDFS and FRB.
- Represent a state member bank in connection with a fair lending investigation by NYDFS.
- Represent two directors of the NYSE exchange into joint investigations by the NY AG and SEC relating to the retirement compensation award to former NYSE chairman and CEO Dick Grasso.
- Represent major non-bank mortgage servicer in connection with investigation by the Ohio Attorney General.
- Represent a global bank in California Attorney General investigation concerning alleged mortgage fraud.
- Represent two major credit unions in connection with an investigation by the Colorado Attorney General into their practices concerning refunds of GAP waiver fees upon consumer prepayment of auto loans.
Technology and Telecommunications
- Successfully represented DISH in connection with actions by State Attorneys General to enjoin the merger of T-Mobile and Sprint, a condition of which was the sale of certain assets to DISH.
- Defended DISH Network at trial in a civil enforcement action brought by the States of California, Illinois, North Carolina and Ohio seeking redress for telemarketing violations under the TCPA and state law.
- Represented a technology company in responding to a Civil Investigative Demand issued by the Texas Attorney General, including challenging the State’s jurisdictional reach.
- Defended an internet network in a Florida attorney general investigation into potential faux news advertising practices.
Consumer Protection Litigation and Investigations
- Obtained dismissal of "private attorney general" false advertising action asserting violations of the District of Columbia's Consumer Protection Procedures Act (CPPA), filed in DC Superior Court.
- Defended an event space provider and its owner in an action brought by the District of Columbia attorney general, alleging violations of the District of Columbia Consumer Protection Procedures Act.
- Lead investigations counsel to Ascension Health and Providence Hospital in the DC attorney general's investigation of both the closure of Providence (2018-2020) and the sale of Providence’s assets (2023-2025). Both investigations resolved successfully, and OAG approved the sale of nonprofit assets to a commercial buyer.
- Represented major internet retailer in multistate AG investigation and related class action litigation pertaining to privacy and data security practices.
- Represented DC-based nonprofit organization in a DC attorney general investigation that resulted in the full closure of the investigation without AG action.
- Represented numerous charities and professional fundraisers in multiple law enforcement investigations brought by the FTC and state attorneys general (in some cases, resulting in full closure of the investigation), including the first joint law enforcement action ever brought against the charity sector by the Federal Trade Commission, 50 state attorneys general, and the attorney general for the District of Columbia.
- Represented a high-profile international 501(c)(3) organization in a nonpublic investigation by the Michigan attorney general's office. The attorney general closed the investigation without taking any action.
- Served as lead counsel for defendant professional charity fundraiser in lawsuit filed by the Minnesota attorney general. Settled on favorable terms after court-ordered mediation, withdrawal of key witness testimony by the attorney general, and removal of a named defendant from the lawsuit.
- Represented a professional solicitor in a nonpublic investigation by the Ohio Attorney General's Office. The attorney general sought a permanent fundraising ban and a significant monetary penalty. Obtained an unprecedented settlement with no fundraising ban.
- Defended an energy supply company against litigations filed by the Pennsylvania attorney general and other state regulators, challenging the energy suppliers' variable-rate advertising, marketing, and pricing practices.
Healthcare
- Defeated an effort by the Texas Attorney General to strip a major Texas hospital of its non-profit status for alleged failure to provide sufficient charity care.
- Counsel in a successful constitutional challenge to a Texas statute burdening a woman's right to obtain an abortion – the US District Court declared the statute unconstitutional, a result not overturned on appeal.