Arizona Attorney General Kris Mayes announced the suit on September 11, a day after her office filed it. Reuters described Arizona as the first state to sue over hair relaxer cancer risk. The 25-page complaint names Dark & Lovely, Optimum, and Mizani, then extends the product list to Bantu, Care Free Curl, Look of Radiance, Roots of Nature, and Ultra Precise. It singles out Dark & Lovely Beautiful Beginnings as a line marketed to children.
The federal cases are a different animal. MDL 3060 held 11,779 pending actions as of the JPML's August 3, 2026 report, all of them personal injury claims waiting on a general-causation admissibility ruling in the Northern District of Illinois. Arizona sued as a sovereign enforcing a disclosure statute. That changes what has to be proven, where, and on what clock.
What Arizona pleaded
The factual core is a knowledge timeline. The complaint walks through the Sister Study and the Black Women's Health Study, then the four publications built on them: White (2021) on ovarian cancer, Chang (2022) on uterine cancer, Bertrand (2023) on uterine cancer in postmenopausal Black women, and Bailey (2025) on thyroid and pancreatic cancer. It alleges that the defendants knew of the Sister Study and the White, Chang, and Bertrand papers when each was published. The Bailey paper is left out of that allegation. It then alleges they kept marketing relaxers as healthy, nourishing, gentle, and safe.
Count One is deception. It pleads two omissions: that the products' safety had never been substantiated, and that the products carry carcinogenic risk. Count Two is unfairness, and it adds selling without substantiating safety and selling products with high estrogenic properties to girls and women without a warning.
The complaint also spends real space on L'Oréal S.A. It alleges the French parent owns the U.S. formulations, holds the relevant patent, manages the financial tracking for U.S. relaxer sales, and dominates the U.S. entities to the point of alter ego. Expect personal jurisdiction over the parent to be one of the first contested motions.
Where causation goes in a disclosure case
L'Oréal's public response already reads like a Rule 702 brief. The company told Consumer Reports that the study underlying the suit called for more research and made no causal finding. In Chicago, that argument decides whether 11,779 cases reach a jury.
In Phoenix it carries less weight, because the statute asks a different question. Section 44-1522(A) makes the omission of a material fact unlawful when made with intent that others rely on it, and it applies whether or not any person was in fact misled, deceived, or damaged. Section 44-1522(C) tells Arizona courts to look to Federal Trade Commission Act interpretations for guidance. That is where the state's substantiation theory gets its footing: FTC doctrine treats a safety claim made without a reasonable basis as deceptive on its own terms.
Read that way, the strongest version of Arizona's case asks two things. First, whether published NIH and Boston University epidemiology on relaxers and hormone-related cancers was a fact a reasonable buyer would want before choosing a product. Second, whether L'Oréal had a basis for calling the products safe and gentle. Neither question requires a finding that relaxers cause cancer. A judge could exclude a causation expert in the MDL and a Maricopa jury could still find the research material to a buyer.
The state did not plead only the narrow version. Paragraph 4 alleges that relaxer use significantly increases the risk of uterine and ovarian cancer, and the requested injunction speaks of significant and potentially terminal health risks. L'Oréal will press on that language. How the court frames the omitted fact, as a documented research finding or as an established risk, is the doctrinal question to watch.
Why the forum matters
The state pleads venue under A.R.S. § 12-401(17) because Maricopa County is the seat of government. It pleads that A.R.S. § 12-510 removes any limitations defense, which matters for marketing conduct the complaint traces to the 1970s. It designates the case Tier 3 under Arizona Rule of Civil Procedure 26.2 and says it will ask for discovery beyond those limits.
The case is also likely to stay put. A state suing in its own name is not a citizen for diversity purposes, and the Supreme Court held in Mississippi ex rel. Hood v. AU Optronics Corp. (2014) that a parens patriae action with the state as sole plaintiff is not a CAFA mass action. The complaint pleads only state-law counts. A removal attempt would have to find a federal question in a state consumer fraud case, which is a hard road.
The result is a case on its own schedule, before an Arizona jury, with no coordination order tying it to MDL 3060 or to the state court proceedings in Illinois, Philadelphia, Georgia, and New York that Special Master Ellen K. Reisman has been working across.
What it means for relaxer inventory
The valuation lever has not moved. Judge Rowland's ruling on general causation still decides whether the federal inventory is worth what firms paid for it, and nothing in Maricopa County changes that ruling's standard or timing.
Arizona adds three things at the margin. The first is a knowledge record. A state enforcement team with mass tort co-counsel will go after what L'Oréal knew about each study and when, and paragraph 70 already pleads actual knowledge. Whether those documents reach MDL plaintiffs depends on the protective order entered in Phoenix, and that order is worth tracking.
The second is defendant concentration. Arizona sued L'Oréal alone. Inventories weighted toward Dark & Lovely and Optimum users now carry a defendant facing penalty exposure pleaded per sale in one state. That exposure sits beside, and apart from, the injury claims. Inventories weighted toward Revlon users sit in the bankruptcy channel and see none of it.
The third is a warning order. If Arizona wins an injunction conditioning sales on cancer warnings, a court will have ordered relaxer cancer labeling in one market before any hair relaxer case has gone to trial. How that plays in injury litigation will be contested, but it would change the labeling landscape L'Oréal defends in every other forum.
The item to watch after L'Oréal's first response is whether other attorneys general follow. Arizona brought this case with outside counsel. The same model is available in any state whose attorney general contracts with private firms, and a second filing would turn a single enforcement action into a settlement variable.