(January 22, 2021, 1:57 PM EST) -- SAN FRANCISCO — An arbitration agreement between an employer and employee that included a nonseverable class action waiver including “representative action[s]” is unenforceable as it encompassed Private Attorneys General Act (PAGA) claims that can’t be waived, a California appellate panel ruled Jan. 20, reversing a trial court’s arbitration order in a putative class complaint alleging violations of California’s unfair competition law (UCL) and wage-and-hour laws....