In Iskanian v. CLS Transportation of Los Angeles,1 an important decision on employment agreements that contain pre-dispute class and collective action waivers, the California Supreme Court held that its prior decision in Gentry v. Superior Court2 was abrogated by U.S. Supreme Court precedent, and that a state’s refusal to enforce a class action waiver on grounds of state public policy or unconscionability is preempted by the Federal Arbitration Act. The California Supreme Court likewise rejected the argument that a class waiver is unlawful under the National Labor Relations Act. However, the state high court also held that neither Supreme Court precedent nor the FAA preempts state law that prohibits waiver of an employee’s right to bring a “representative” action under California’s Private Attorneys General Act.