By Jennifer Riley and David Ross
Many thought that the U.S. Supreme Court’s recent decisions in AT&T Mobility v. Concepcion, 131 S.Ct. 1740 (2011), and CompuCredit Corp. v. Greenwood, 132 S.Ct. 665 (2012), had firmly established that private arbitration agreements with class action waivers were enforceable under the Federal Arbitration Act (“FAA”). However, the National Labor Relations Board