Crystal Christman brought a claim against her former employers for Labor Code violations under California’s Private Attorneys General Act of 2004 (“PAGA”). Defendants filed a petition to compel individual arbitration of Christman’s PAGA claim. The trial court denied defendants’ petition, concluding that PAGA claims are not subject to arbitration, and that Christman’s claim could not be split into a nonarbitrable representative claim and an arbitrable individual claim. The Court of Appeal affirmed the trial court’s ruling.