On June 15, 2022, in an 8-1 decision authored by Justice Alito in Viking River Cruises, Inc. v. Moriana, 596 U.S. __, 2022 WL 2135491 (June 15, 2022), the U.S. Supreme Court concluded that individual claims brought under the California Labor Code Private Attorneys General Act (PAGA), which authorizes employees to act as private attorneys general by bringing claims against employers “on behalf of himself or herself and other current or former employees,” are arbitrable under the Federal Arbitration Act (FAA). Although the Court further held that the FAA did not preempt the California Supreme Court holding in Iskanian v. CLS Transportation Los Angeles, LLC that a wholesale waiver of an employee’s right to bring a PAGA action is contrary to California public policy and therefore unenforceable, the Court interpreted PAGA to require a plaintiff to bring an individual PAGA suit in order to have standing to bring a representative PAGA claim. Therefore, the Court held that once the individual PAGA claim is sent to arbitration, non-individual PAGA claims must be dismissed for lack of standing.