Eliminating a California state court carve-out to the types of claims that are required to be arbitrated, the Ninth Circuit held that claims seeking public injunctive relief are arbitrable and that prohibitions against arbitrating such claims are preempted. Ferguson v. Corinthian Colleges, Inc., 733 F.3d 928 (9th Cir. 2013) (No. 11-56965). Previously, the California Supreme Court had exempted claims for public injunctive relief from arbitration. The Ninth Circuit concluded, however, that this exemption was preempted by the FAA, because it was an exemption that prohibited outright arbitration of a particular type of claim.