In Securitas Security Services USA, Inc. v. Superior Court (2015) 234 Cal.App.4th 1109, the appellate court held that an agreement's PAGA waiver violated public policy, notwithstanding that the employee was not required to enter into it as a condition of employment. (Securitas, at p. 1121.) As the court explained, "Iskanian's underlying public policy rationale--that a PAGA waiver circumvents the Legislature's intent to empower employees to enforce the Labor Code as agency representatives and harms the state's interest in enforcing the Labor Code--does not turn on how the employer and employee entered into the agreement, or the mandatory or voluntary nature of the employee's initial consent to the agreement." (Id. at p. 1122.) The reason is that "a PAGA claim provides a remedy inuring to the state and the public, and the law ... broadly precludes private agreements to waive such public rights." (Ibid.)