In a move that will undoubtedly frustrate California employers, the United States Supreme Court has denied review of Bridgestone Retail Operations v. Milton Brown, a California Supreme Court case which held that Private Attorney General Act waivers in employment arbitration agreements are not enforceable. The refusal to review this case comes on the heels of the U.S. Supreme Court’s decision to deny review of Iskanian v. CLS Transportation, the first case which sought review by the Court of this issue. The petitions seeking review of the Bridgestone and Iskanian cases argued that these decisions conflict with the U.S. Supreme Court’s decision in Concepcion v. AT&T Mobility, a case which held that the Federal Arbitration Act preempted state public policy in favor of class actions. As a result, the current split between federal courts and California state courts on the enforceability of PAGA waivers in employment arbitration agreements will remain unresolved.