On June 29, 2026, in a 6-3 decision, the U.S. Supreme Court held that (1) the Federal Trade Commission’s (FTC) statutory “for‑cause” removal protection for Commissioners violates the Constitution’s separation of powers and (2) President Trump lawfully removed Rebecca Slaughter from the FTC. The Court concluded that because FTC Commissioners
Continue Reading Supreme Court Holds FTC Removal Protections Unconstitutional
Jehan Patterson
Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection matters.
Jehan is a member of the Advertising and Consumer Protection Investigations group. She represents corporate and individual clients in consumer protection investigations and litigation by the FTC and state Attorneys General and state financial regulators. She advises clients on consumer protection considerations relating to generative and agentic artificial intelligence, state and federal laws governing autorenewal programs, sustainability and other environmental claims, the FTC’s Made in USA rule, the USDA’s National Organic Program, adtech, and other advertising matters. Jehan also represents clients in complex civil litigation involving consumer protection claims.
Before joining Covington, Jehan was a Senior Litigation Counsel in the Office of Enforcement at the Consumer Financial Protection Bureau, where she led investigations into numerous providers of consumer financial products and services for violations of federal consumer financial laws and regulations, including the Consumer Financial Protection Act’s prohibition against unfair, deceptive, and abusive acts and practices.
Washington Anti-Spam Law Decision Addresses Article III Standing in CEMA Cases
A federal court recently addressed whether plaintiffs alleging misleading commercial email practices in violation of Washington’s Commercial Electronic Mail Act (“CEMA”) have Article III standing to pursue claims. The ruling suggests that alleged violations of CEMA, standing alone, could constitute a concrete injury for Article III standing, where the asserted…
Continue Reading Washington Anti-Spam Law Decision Addresses Article III Standing in CEMA CasesDC AG Sues Multifamily Landlord Over Alleged Deceptive Rental Fee Advertising
On April 27, 2026, District of Columbia Attorney General Brian L. Schwalb filed a complaint against Mid‑America Apartment Communities, Inc., and its subsidiaries (collectively, “MAA”) alleging that the landlord charged illegal fees and misled prospective tenants about the true cost of rent. This action is the latest example of state…
Continue Reading DC AG Sues Multifamily Landlord Over Alleged Deceptive Rental Fee AdvertisingFTC Sweep on “Made in the USA” Claims
On April 14, 2026, the FTC announced three settlements and issued closing letters to two additional companies concerning “Made in America,” “Made in the USA,” and similar U.S.‑origin claims (collectively, “MUSA claims”). These actions reflect the FTC’s continued focus on MUSA claims and, more broadly, the Trump administration’s focus on…
Continue Reading FTC Sweep on “Made in the USA” ClaimsFTC Seeks Public Comment on Proposed Rulemaking for Unfair or Deceptive Rental Housing Fee Practices
On March 12, 2026, the Federal Trade Commission (“FTC”) announced an Advanced Notice of Proposed Rulemaking (“ANPRM”) seeking public comment on a proposed rulemaking focusing on potential unfair or deceptive acts or practices in the rental housing market. This ANPRM contemplates requiring landlords and property managers to provide full…
Continue Reading FTC Seeks Public Comment on Proposed Rulemaking for Unfair or Deceptive Rental Housing Fee PracticesFTC Negative Option Rule ANPRM
On March 11, 2026, the Federal Trade Commission (“FTC” or “the Commission”) announced an Advanced Notice of Proposed Rulemaking (“ANPRM”) regarding its Rule Concerning the Use of Prenotification Negative Option Plans, commonly known as the Negative Option Rule (“the Rule”). This ANPRM signals the beginning of a rulemaking process that…
Continue Reading FTC Negative Option Rule ANPRMFTC Issues Warning Letters for Violations of Consumer Reviews Rule
The Federal Trade Commission (FTC) sent letters to 10 companies—whose identities were not publicly disclosed—on December 22, 2025, warning them about potential violations of the Consumer Reviews Rule. The Rule, which took effect in October 2024, targets deceptive online review and testimonial practices. These warning letters mark the FTC’s first…
Continue Reading FTC Issues Warning Letters for Violations of Consumer Reviews RuleGreystar’s $24 Million Settlement Signals FTC Crackdown on Hidden Rental Fee
On December 2, Greystar agreed to a $24 million settlement over allegations it misled renters by omitting mandatory fees from advertised monthly rents. This settlement underscores the FTC’s continuing scrutiny of “junk fees” and signals that the FTC may pursue rulemaking requiring greater transparency in rental fee advertising.
The FTC…
Continue Reading Greystar’s $24 Million Settlement Signals FTC Crackdown on Hidden Rental FeeFTC Sues LA Fitness Operators for Unfair Gym Cancellation Policies
On August 20, 2025, the Federal Trade Commission (“FTC”) sued Fitness International, LLC and Fitness & Sports Club LLC – the parent companies of LA Fitness and other gym chains – for violations of Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act (“ROSCA”) in connection with…
Continue Reading FTC Sues LA Fitness Operators for Unfair Gym Cancellation PoliciesFTC Secures $14 Million Settlement with Match Group Over Deceptive Subscription Practices
In August, the Federal Trade Commission (“FTC”) announced a $14 million settlement with Match Group, Inc. and Match Group, LLC (collectively, “Match”), the parent companies of online dating platforms Match.com, OkCupid, PlentyOfFish, and other dating sites. In addition to monetary relief, the settlement includes significant injunctive provisions aimed at addressing…
Continue Reading FTC Secures $14 Million Settlement with Match Group Over Deceptive Subscription Practices