By Cary Sullivan and Chris Waidelich, Jones Day (May 3, 2017, 11:18 AM EDT) -- Earlier this month, the California Supreme Court, in McGill v. Citibank NA, No. S224086, Slip Op. at 1 (Cal. Apr. 6, 2017), unanimously held that "that the [Federal Arbitration Act] does not require enforcement of a provision in a predispute arbitration agreement that, in violation of generally applicable California contract law, waives the right to seek in any forum public injunctive relief under the UCL [Unfair Competition Law], the CLRA [Consumer Legal Remedies Act], or the false advertising law [FAL]" (emphasis added). This narrow exception, however, does not foreclose the possibility of arbitrating public injunctive relief claims....