Last week, the Supreme Court denied review in Brown v. Ralphs Grocery Co., no. S195850. Justice Baxter voted to grant review.
That is the case in which the Court of Appeal affirmed an order striking down an arbitration clause in a representative PAGA action for Labor Code violations, notwithstanding Concepcion. Brown v. Ralphs Grocery Co., 197 Cal.App.4th 489 (2011) (Second Appellate District, Division Five). My original post on the case is here.
It is certainly possible that the defendant may seek review in the U.S. Supreme Court.