Orrick State Attorneys General Update | June 2026


8 minute read | June.09.2026

Florida Attorney General Subpoenas Environmental Law Institute Over Judicial Trainings and Climate Change Litigation

State AG enforcement efforts targeting climate-related organizations are expanding in scope to include nonprofits involved in judicial education.

Florida Attorney General James Uthmeier issued a civil investigative subpoena to the Environmental Law Institute (ELI) and its Climate Judiciary Project (CJP) under the Florida Deceptive and Unfair Trade Practices Act. The subpoena focuses on whether CJP and its advisors promoted advocacy-oriented positions on climate litigation while presenting themselves as impartial judicial educators.

The AG requests communications and documents related to specific academics, advisors, and collaborators associated with climate litigation, climate attribution science, or public advocacy on fossil fuel accountability. The subpoena specifically references work by individuals connected to amicus briefs, public petitions, or litigation-related advocacy. It also seeks records of communications with plaintiffs' attorneys in climate lawsuits, disclosures regarding funding and advisor activities, responses to congressional inquiries, and materials related to judicial education initiatives such as "Aspirational Judging" and climate science training programs.

The subpoena also seeks records concerning the organizations’ funding, communications, educational programs, and interactions with judges, particularly in Florida. It demands documents relating to private and public funding sources, including donor agreements, communications with philanthropic organizations, and any financial connections to climate litigation efforts. The subpoena also requests records concerning seminars, judicial trainings, curricula, webinar transcripts, attendance by Florida judges, disclosures made to participants, and communications between CJP personnel and judges.

California Attorney General Issues Proposed Regulations to Implement Newly Enacted  Social Media Law Meant to Protect Children

California’s new proposed regulations would require platforms to implement age verification, parental consent processes, data minimization, and public reporting obligations.

California Attorney General Rob Bonta released proposed regulations that would implement California’s “Protecting Our Kids from Social Media Addiction Act” (SB 976). The new law restricts social media platforms from providing “addictive feeds” and certain notifications to minors without parental consent. The draft regulations establish detailed standards for how online platforms must determine whether a user is under 18.

Operators are required to use “commercially reasonable and technically feasible” age-assurance methods, which may include biometric analysis, behavioral data, cryptographic verification tools, or government-issued identification, (though identification cannot be the sole method used. Platforms must also publish public reports explaining their age-assurance methods, accuracy testing, anti-fraud safeguards, and bias mitigation efforts. The regulations emphasize data minimization, requiring any information collected for age verification to be limited, securely stored, and deleted once no longer necessary. 

The proposal also creates extensive procedural requirements for parental consent and user appeals. Before seeking parental consent, operators must notify minors that certain platform features cannot legally be provided without such consent and must first obtain the minor’s permission to contact the parent. Platforms must offer at least one parental consent method that does not require creating an account, making a purchase, or submitting government identification. Both minors and parents must be able to revoke consent easily at any time. In addition, operators are required to maintain systems for detecting fraud, circumvention, and misuse of age-verification tools, including emerging risks such as deepfakes or falsified data.

The regulations further require platforms to investigate reports suggesting a user may be a minor and to apply minor-status determinations consistently across all versions of a service, including apps and websites.

The proposed rulemaking is currently in the formal notice-and-comment phase of California’s administrative rulemaking process. The proposed regulations were released on May 14, 2026, with a 45-day public comment period. Written comments must be submitted by June 30, 2026. During this same period, stakeholders – including technology companies, advocacy groups, academics, parents, and members of the public – can review the draft rules and submit feedback by email or mail.

California Raises Consumer Protection Concerns about FIFA’s World Cup Ticket Sales

California AG is raising concerns that World Cup ticket sales may have violated state consumer protection laws and requested detailed information about FIFA's ticketing practices.

California Attorney General Rob Bonta sent a letter to the Fédération Internationale de Football Association (FIFA), regarding ticket sales for the upcoming World Cup.The letter raises concerns that ticket sales for the 2026 FIFA World Cup in California may have violated California consumer protection laws. The letter focuses on reports that FIFA sold tickets based on stadium seating maps displaying certain categories but later changed those categorizations before assigning exact seats. According to the Attorney General, some consumers may have paid premium prices expecting seats in one area, only to receive seats that had previously been classified differently. The letter states that California law prohibits misleading marketing practices and that disclaimers or fine print may not shield companies from liability if consumers were likely misled.

The Attorney General requests detailed information from FIFA about how ticket categories were displayed, how seating assignments changed across sales phases, what disclosures were provided to consumers, and whether refunds or remedies were offered to affected purchasers. The letter also emphasizes the significance of the World Cup for California fans and stresses that consumers should be able to rely on the representations made during ticket sales. The inquiry is part of an ongoing review by the California AG to determine whether enforcement action or further investigation may be warranted.

Connecticut Attorney General Issues Memorandum Regarding Artificial Intelligence

A major focus of the memorandum is the application of Connecticut's civil rights and consumer protection laws to AI-assisted decision-making.

Connecticut Attorney General William Tong issued an AI advisory memorandum to state agencies clarifying that AI technologies are already subject to existing state and federal laws, even in the absence of comprehensive AI-specific legislation. The memo emphasizes that AI systems do not operate in a "regulatory vacuum" and that companies remain legally accountable when AI tools are used in ways that violate civil rights, consumer protection, privacy, data security, or antitrust laws. The memorandum highlights growing concerns about algorithmic bias, misinformation, deepfakes, manipulation of children, and misuse of personal data, while also recognizing AI’s potential economic and social benefits.

The guidance makes clear that businesses using AI in employment, housing, lending, healthcare, education, or insurance may still be liable for unlawful discrimination if automated systems create disparate impacts on protected groups. The advisory stresses that responsibility cannot be shifted to algorithms or vendors, and that organizations deploying AI must monitor systems for fairness, transparency, and accuracy. The memorandum also warns that deceptive or misleading AI practices—including undisclosed chatbot behavior, manipulative design, or false AI-generated content—may trigger enforcement actions under the Connecticut Unfair Trade Practices Act (CUTPA).

The memorandum further explains how the Connecticut Data Privacy Act (CTDPA) governs AI systems that collect or process personal information. Organizations must:

  • Provide meaningful disclosures about AI-related data uses,
  • Obtain consent for sensitive data processing, and
  • Conduct risk assessments when AI profiling could significantly affect consumers.

The advisory underscores heightened obligations regarding biometric data, children’s data, health information, and other sensitive categories. It also signals an aggressive enforcement posture from the Attorney General’s Office, particularly around harms to minors and chatbot safety, while complementing broader legislative efforts underway in Connecticut to strengthen AI governance and consumer protections.

States Settle with Data Analytics Firm Over Alleged Antitrust Violations

The settlement underscores that data-sharing and benchmarking services, even those offering anonymized or aggregated data, can face antitrust liability if they facilitate the exchange of competitively sensitive information.

A bipartisan group of state attorneys general announced a settlement with Agri Stats, Inc., a company that provides benchmarking and data-reporting services to meat processors, over allegations the company illegally drove up the prices of chicken, pork, and turkey.

The final stipulation and order resolves an antitrust lawsuit brought by the United States and several states, including Tennessee, against Agri Stats, Inc. The government alleged that Agri Stats' reports enabled poultry, pork, and turkey processors to share competitively sensitive information in ways that could reduce competition and facilitate coordinated pricing or production behavior in violation of Section 1 of the Sherman Act. The settlement does not require Agri Stats to admit wrongdoing, but it imposes extensive restrictions and compliance obligations designed to prevent the sharing of sensitive non-public business information.

A central feature of the judgment is the prohibition on Agri Stats’ sales-reporting practices. The company must stop offering certain "Sales Report Books" and generally cannot report or retain sales data that could reveal pricing behavior, even in anonymized form, except for narrow operational purposes. The judgment also bars Agri Stats from identifying participating companies, publishing rankings, revealing “flags” that disclose the number of contributors to a dataset, or reporting individual company information except in limited aggregated or statistical formats. To preserve confidentiality and reduce anticompetitive risks, the order requires that aggregated reports must contain data from multiple processors, and no single company may dominate reported metrics.

The judgment additionally imposes broad transparency and access requirements. Agri Stats must make many of its reports and manuals available to non-meat processors on nondiscriminatory terms and cannot use pricing or contractual barriers to restrict access. The order establishes oversight mechanisms for any new reporting products and limits how Agri Stats’ subsidiary, EMI, may continue publishing nationwide price reports. EMI may maintain certain public pricing reports only if they avoid revealing contributor identities and comply with strict market-share and confidentiality thresholds. Overall, the judgment seeks to preserve legitimate benchmarking functions while preventing the exchange of detailed competitive data that regulators believe could undermine fair competition in U.S. meat-processing markets.