In June of 2014 the California Supreme Court upheld the enforceability of mandatory pre-dispute arbitration provisions contained in an employment agreement, and also upheld the enforceability of class action waiver provisions. Iskanian v. CLS Transportation Los Angeles, LLC. This provides employers with a significant shield against the previous onslaught of class action wage and hour cases. However, the ruling was not a complete victory. The Court also ruled that actions brought under the Labor Code Private Attorneys General Act of 2004 (PAGA) (Lab.Code §2698 et.seq.) are not subject to mandatory arbitration and that an arbitration agreement requiring an employee to give up the right to bring a representative action under PAGA is contrary to “public policy” and therefore void. The result is that while most employers will appropriately use arbitration and class action waivers as part of the employment agreement, the exposure to PAGA claims brought in a court of law still remains. Plaintiff attorneys have learned from this decision and re-tooled complaints to focus on PAGA claims. We will discuss: (1) the legal basis for PAGA claims (2) procedural issues and (3) strategies in defending against PAGA claims.