State Attorneys General Investigations

Williams & Connolly routinely handles investigations brought by state attorneys general. These matters included single jurisdiction and multi-state investigations and involve virtually every aspect of government oversight that companies face today. Many times these investigations also include Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) involvement, including Foreign Corrupt Practices Act (“FCPA”) issues.

The firm has dealt with attorneys general from (among others) Alabama, Alaska, California, Florida, Hawaii, Idaho, Illinois, Kentucky, Massachusetts, Mississippi, Nevada, New Jersey, New York, Oklahoma, Oregon, South Carolina, Tennessee, Texas, Utah, Virginia, Washington, and West Virginia.

Representative Experience

Though all cases vary and none is predictive, Williams & Connolly’s recent representations include:

  • A Fortune 250 company in connection with alleged overcharging of government entities on federal, state, and local government contracts.
  • Cardinal Health in multistate investigation by 39 state attorneys general in connection with distribution of opioid medications.
  • A multinational investment bank in state attorney general, SEC, and DOJ investigations regarding allegations of bid-rigging in municipal securities industry.
  • One of the largest health corporations in the United States in an investigation by the Texas Attorney General’s office concerning generic drug discount programs and price-matching.
  • A pharmaceutical manufacturer in multi-state proceedings regarding Average Wholesale Price (“AWP”), including trial involving claims brought by the Kentucky State Attorney General.
  • A leading life settlement provider and several of its affiliates in civil enforcement action brought by the New York Attorney General.
  • State attorneys general investigations of specialty pharmacy for allegations of consumer-fraud and Medicaid fraud/kickback.
  • A pharmaceutical company in combined federal and multi-state attorneys general investigations for alleged off-label promotion. Williams & Connolly handled investigations and “white paper” submission.
  • A Fortune 100 company in multiple state attorneys general investigations into whether alleged contract breaches were false claims, including via Implied Certification Theory. 
  • Medco Health Solutions in New Jersey state court regarding the enforceability of subpoenas for testimony.
  • SEC and New York attorney general investigations regarding use of placement agents in context of public employee pension fund investments.
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