State Attorneys General Investigations & Enforcement

State AGs and other state regulators are increasingly pursuing high-risk investigations and enforcement actions across every major U.S. industry. Companies facing state AG scrutiny require a team with the specific experience, relationships and strategic insight into state AG dynamics to navigate these challenges effectively.

At Paul Hastings, we combine elite capabilities across government investigations, antitrust, complex litigation, privacy and cybersecurity, environmental and employment law to provide comprehensive support for companies under state AG investigation.

State authorities pursue matters in the areas of consumer protection, data privacy and cybersecurity, antitrust and unfair competition, artificial intelligence (AI), healthcare, financial services and employment law, as well as diversity, equity and inclusion (DEI)and environmental, social and governance (ESG). They also are increasingly collaborating with plaintiffs’ lawyers, amplifying enforcement risks. Our team has unmatched experience in these areas.

Coordinated Defense Across State and Federal Agencies

In today’s regulatory landscape, companies frequently face simultaneous federal and state investigations, often with overlapping jurisdictional claims and competing enforcement priorities. Successfully navigating these parallel proceedings requires a team that understands the interplay between these parties and can harmonize conflicting demands to achieve the best outcome. We have led defense efforts in matters involving dozens of states, coordinated parallel investigations with federal agencies and litigated precedent-setting cases initiated by individual AG offices.

Paul Hastings excels at managing these multifront battles. We have extensive experience coordinating defense strategies across multiple enforcement bodies — balancing the interests of state AGs, the DOJ, SEC, FTC, CFPB and other agencies — to minimize risk and avoid contradictory resolutions. Our strategic approach ensures that companies remain proactive rather than reactive, mitigating unnecessary exposure while maintaining compliance and business continuity.

A Deep Bench of Former Government and In-House Counsel

We have cultivated strong working relationships with state AG offices and other state agencies nationwide, regularly engaging with key decisionmakers to preempt and resolve investigations and enforcement actions. Our team includes former front-office state AG staff, senior federal and state regulatory enforcement lawyers, in-house counsel and federal prosecutors who can bring insider perspectives into matters involving state AGs and other state regulators. Our experience includes representing clients in multistate proceedings as well as individual formal investigations, informal inquiries, civil and criminal litigation, and other complex regulatory matters.

Our State AG Experience Includes:

• Multistate Investigations and Settlements: Defending Fortune 100 and midsized companies in complex AG-led inquiries.
• Consumer Protection: Resolving cases for clients defending allegations by state regulators of fraud, deceptive trade practices and regulatory violations.
• Consumer Financial Services: Representing banks, fintechs, nonbank lenders and other industry participants in investigations involving deposits, payments, lending, leasing, servicing, collection, credit reporting and related activity across the full spectrum of financial products and services in federal and state government investigations.
• Antitrust and Competition Matters: Resolving state AG-led merger challenges and competition disputes.
• Regulatory Compliance and Risk Mitigation: Providing proactive counseling to companies, financial institutions and other regulated entities to minimize state regulator enforcement risks before they arise.
• Employment and Workplace Investigations: Defending employers in state AG investigations and litigation related to pay equity, compensation, hiring, promotions, harassment and other employment practices.
• DEI and ESG Advisory: Counseling on DEI and ESG-related initiatives, including against AG scrutiny of environmental claims, investment disclosures and corporate social responsibility statements.
• Privacy, Cybersecurity and Data Breach Response: Guiding clients through multistate AG investigations tied to data incidents, privacy violations and compliance with breach notification laws.

Landmark Representations

We have successfully led some of the most high-profile, high-stakes AG matters in the country. Many of the representations we handle are nonpublic and resolved without public enforcement action.

• Led the defense of Activision Blizzard in a high-profile case involving both state and federal agencies. After nearly three years of litigation, a resolution was reached that The Wall Street Journal described as “California’s Surrender on Activision Blizzard.” The court-approved settlement resulted in the dismissal of systemic harassment claims and was less than 5% percent of the damages originally sought, with government recitals confirming the absence of systemic unlawful employment practices.
• National co-lead coordinating counsel for Wells Fargo Bank in a $575 million resolution with all 50 state AGs and D.C., addressing consumer claims in one of the largest and most comprehensive multistate AG settlements ever reached.
• Led the resolution of a $33 million settlement with 44 states regarding the promotion of an antipsychotic medication and a $45 million settlement with 34 states around the promotion of Zyvox and Lyrica.
• Represented Berkshire Hathaway subsidiaries Home Services of America, Trident Mortgage and Fox & Roach in parallel DOJ, CFPB and state AG investigations involving fair lending issues, securing coordinated and favorable resolutions.
• Defended a midsized pharmaceutical company in a confidential state AG investigation into patient support programs and pricing issues that was successfully resolved with no enforcement action.
• A former in-house counsel on our team played a central role in negotiating and finalizing the $2.3 billion global resolution of a non-steroidal anti-inflammatory drug matter — the largest criminal healthcare settlement at the time — with DOJ, HHS OIG and dozens of State Medicaid Fraud Control Units. That same counsel also led the $491 million resolution of an immunosuppressant medication and coordinated associated Corporate Integrity Agreement negotiations and consumer protection settlements.
• Representing a mortgage servicer in a Massachusetts AG investigation regarding default servicing and loss-mitigation practices under state law.
• Successfully represented a bank in coordinated DOJ and New York AG investigation resulting in closure of the matter without further action
• Represented prominent a mortgage industry participant in parallel investigations by the federal government and numerous state AGs.
• Representing a large conglomerate, with numerous affiliates performing retail sales, consumer lending and related services, in a multistate attorney general investigation.
• Represented a top 10 bank in New York AG investigation and consensual resolution relating to deposit accounts.
• Represented a loan servicer in several AG investigations that were closed without further action.