VIKING RIVER CRUISES, INC., PETITIONER v. ANGIE MORIANA, 596 U.S. 639

Summary

HOLDINGS: [1]-FAA preempted California's Iskanian rule insofar as it precluded division of the Private Attorneys General Act (PAGA), Cal. Lab. Code § 2698 et seq. (2022), actions into individual and non-individual claims through an agreement to arbitrate. State law could not condition enforceability of an arbitration agreement on the availability of a procedural mechanism that expanded the scope of arbitration by introducing claims that parties had not agreed to arbitrate; [2]-Reversal was warranted as the agreement's severability clause provided that any portion of the waiver that remained valid had to be enforced in arbitration. Thus, an employer was entitled to enforce the agreement insofar as it mandated arbitration of n employee’s individual PAGA claim. Because her individual dispute had been pared away, the employee lacked statutory standing on the non-individual claims.