On The Continuing Relevance Of State Antitrust Enforcement In The US

In recent years, the initiation of state enforcement actions and settlements for alleged antitrust violations has rebounded from a lull in 2021 and 2022.¹ In 2025, the states collectively filed actions or announced settlements in five single-state matters, participated or joined with the Federal Trade Commission (FTC) in four other matters and joined with the Antitrust pision of the Department of Justice (DOJ) in another matter. In contrast, in 2021, the states filed just one action alongside the DOJ, plus three actions on their own, and in 2022 they filed one action together with the FTC and five on their own.² The number of actions remains below a recent high-water mark set in 2019, when the states collectively initiated 12 actions or settlements, joined with the FTC in one other action, and joined with DOJ in another action.