On June 23, the California Supreme Court held that the Federal Arbitration Act (FAA) preempts state law issues that restrict enforcement of class action waivers in arbitration agreements, such as public policy or unconscionability.  Iskanian v. CLS Transp. Los Angeles, LLC, 327 P.3d 129 (Cal. 2014) (No. S204032).  Here, an employee sought to bring a class action lawsuit against an employer.  The employee had entered into an arbitration agreement that waived the right to class proceedings.  The court ruled that a state’s refusal to enforce such a waiver on grounds of public policy or unconscionability is preempted by the FAA.  The court noted, however, that the employee also sought to bring a representative action under a California statute (PAGA) that authorizes an employee to file suit as a private attorney general on behalf of the state against an employer for labor code violations committed against the employee and fellow employees.  The court found that an arbitration agreement requiring an employee as a condition of employment to give up the right to bring a PAGA action is contrary to public policy.   The court further found that the FAA’s goal of promoting arbitration as a means of private dispute resolution does not prohibit the state legislature from deputizing employees to prosecute labor code violations on the state’s behalf.   Therefore, the FAA does not preempt a state law that prohibits waiver of PAGA representative actions in an employment agreement.