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State AG News: Environment, Mispriced Items, Data Exploitation (November 20-26, 2025)

By Toni Michelle Jackson, Daniel Leff & Julian Lafaurie on December 1, 2025
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Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken. See our State Attorneys General page for more insights. Below are the updates from November 20-26, 2025:

Multistate

  • A multistate coalition of 20 attorneys general succeeded in protecting four federal agencies from elimination by Executive Order. The United States District Court for the District of Rhode Island granted the coalition’s motion for summary judgement, permanently enjoining the dismantling of the Institute of Museum and Library Services (IMLS), the Minority Business Development Agency (MBDA), the Federal Mediation and Conciliation Service (FMCS), and the U.S. Interagency Council on Homelessness (USICH).
  • A multistate coalition of 20 attorneys general announced a suit against the U.S. Department of Housing and Urban Development (HUD) in response to new restrictions on Continuum of Care grant programs. Those restrictions will reduce the grant funds available for permanent housing and housing continuity programs.  The coalition asserts that HUD’s proposed changes are unlawful because HUD did not engage in the appropriate rulemaking procedures and did not receive congressional approval for the changes.
  • A multistate coalition of 17 attorneys general filed a comment letter with the Environmental Protection Agency (“EPA”) opposing a new rule that would relax the gradual phaseout of HFC use created by the AIM Act. The coalition argued that EPA’s new HFC standards would allow industries to reintroduce an extremely powerful greenhouse gas back into the environment.
  • A coalition of eight attorneys general entered a settlement with Greystar Management after alleging that Greystar used RealPage’s AI software to raise rent prices in violation of antitrust law. The settlement requires Greystar Management to pay $7 million and stop using any third-party algorithmic pricing models. 

California

  • Attorney General Rob Bonta reached a settlement agreement with Jam City regarding the company’s alleged failure to provide consumers with a method to opt-out of the sale of their personal information. The settlement agreement requires Jam City to pay $1.4 million and prohibits Jam City from selling the personal information of consumers aged 13-16 without their express consent.

Colorado

  • Attorney General Phil Weiser entered into a settlement agreement with Instawork, an app based staffing agency in Colorado. The Attorney General alleged that Instawork misclassified employees as independent contractors and failed to pay required unemployment insurance premiums. The settlement is the first of its kind under the Colorado False Claims Act. 

Michigan

  • Attorney General Dana Nessel issued a Notice of Intended Action to retail chain Five Below. The Notice alleged that Five Below violated the Michigan Shopping Reform Act and Michigan Consumer Protection Act by overcharging consumers through a consistent practice of mislabeling retail items with prices lower than the actual price charged at the register.

West Virginia

  • West Virginia Attorney General JB McCuskey sued Express Scripts, claiming that the company was responsible for the oversupply of opioids in the state. The suit argues that Express Scripts boosted sales by undermining safeguards intended to prevent improper prescribing.
Tags: AI
Photo of Toni Michelle Jackson Toni Michelle Jackson

Toni Michelle Jackson is a first-chair litigator whose extensive jury and bench trial experience is informed by over 15 years of government service. Clients rely on her to marshal the evidence presented during discovery and either win their case at summary judgment or…

Toni Michelle Jackson is a first-chair litigator whose extensive jury and bench trial experience is informed by over 15 years of government service. Clients rely on her to marshal the evidence presented during discovery and either win their case at summary judgment or try the case and win at trial. In particular, she leads class/collective actions, multidistrict litigations, and other complex litigation in federal and state courts. As chair of the State Attorneys General Practice Group, Toni provides advice and counsel to clients with State Attorneys General matters, including investigations, inquiries and litigation.

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Photo of Daniel Leff Daniel Leff

Daniel Leff is an antitrust litigator, trial lawyer, and strategic advisor. As a former state assistant attorney general, he draws on his experience litigating complex, high-profile antitrust cases for clients involved in or anticipating litigation as both plaintiffs and defendants. Dan also counsels

…

Daniel Leff is an antitrust litigator, trial lawyer, and strategic advisor. As a former state assistant attorney general, he draws on his experience litigating complex, high-profile antitrust cases for clients involved in or anticipating litigation as both plaintiffs and defendants. Dan also counsels and advocates for companies seeking antitrust regulatory approval for mergers, acquisitions, and innovative business deals.

Dan joined Crowell from the Massachusetts Attorney General’s Office (AGO), where he served in the Office’s Antitrust Division. In that role, he worked hand-in-hand with enforcers from the U.S. Department of Justice (DOJ), the Federal Trade Commission (FTC), and the attorney general offices of nearly every U.S. state and territory to investigate and litigate merger, monopolization, and cartel matters.

His work with the AGO included successfully trying merger and Sherman Act § 1 cases in federal court. He was also a lead member of a plaintiff group comprising nearly every state attorney general office in the country in a large pharmaceutical price-fixing multidistrict litigation (MDL).

Dan also investigated, litigated, and settled numerous competition matters in industries including telecommunications, transportation, energy, agricultural products, healthcare, and pharmaceuticals. Clients benefit from Dan’s experience in the Sherman, Clayton, and FTC acts and numerous state antitrust and consumer protection statutes, as well as his familiarity with the perspectives of state and federal enforcers across the country.

Dan began his career at Crowell, where he represented clients facing federal and state antitrust, consumer protection, and environmental scrutiny, primarily in the telecommunications and energy industries. He also previously worked for an international law firm in Boston, representing pharmaceutical and medical device companies facing federal civil and criminal investigations.

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  • Posted in:
    Environmental and Climate, Government and Public Policy
  • Blog:
    State AG Blog
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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