A federal district court refused to enforce arbitration agreements that were entered while FLSA litigation already was pending, in which employees were presented by their employer with an arbitration agreement that bound the employees to arbitrate any FLSA claims. Billingsley v. Citi Trends, Inc.,No. 12-0627 (N.D. Ala. Jan. 23, 2013). The court found that the meetings between the employer and employees were cause for concern, because in cases in which the employer has an obvious interest in diminishing the size of the potential class, a risk exists that these types of unsupervised communications will sabotage the employees’ independent decision-making regarding their involvement in the action. Accordingly, the court allowed any potential plaintiffs who felt they signed the arbitration agreement under duress to opt-in to the class action.