The U.S. Supreme Court has refused to review the decision of the California Court of Appeals in Athens Disposal Co. v. Franco, which held that an arbitration agreement between a trash company and a driver that included a waiver of class claims and prohibited the employee from seeking civil penalties on behalf of other workers was unconscionable and so tainted with illegality that it was unenforceable. See Athens Disposal Co. v. Franco, U.S., No. 09-272, cert. denied, January 11, 2010.