California is in the midst of a long-running battle over the enforceability of representative-action waivers in employment contracts. While this battle has not been fully resolved, recent case law indicates that representative private-attorney-general actions will not soon be eliminated by waivers in employer-imposed arbitration agreements. Practitioners may assume that California will continue to rely on representative actions brought by employees pursuant to the Labor Code Private Attorneys General Act (PAGA) to ensure compliance with the state’s labor laws and to “supplement enforcement actions by public agencies.”