In Iskanian v. CLS Transp. Los Angeles, LLC (2014) 59 Cal.4th 348, it confirmed that "an employee's right to bring a PAGA action is unwaivable," and thus "an agreement by employees to waive their right to bring a PAGA action . . . is against public policy and may not be enforced. " (Id. at p. 383.) It also held that "the FAA does not preempt a state law that prohibits waiver of PAGA representative actions in an employment contract." (Id. at p. 359; see also id. at pp. 384-389.)