On March 10, 2009, a California appellate court held that an employee’s agreement to arbitrate on an individual basis was unenforceable with respect to a plaintiff-employee who had filed a putative class-action lawsuit alleging the denial of meal and rest periods. Franco v. Athens Disposal Co., Inc., case no. B203317. Franco is the latest in a string of decisions in which California state courts have declined to enforce class-arbitration waivers in the employment context.