Two recent decisions from the U.S. Court of Appeals for the Second Circuit have reaffirmed the enforceability of employment-related arbitration agreements containing class action waivers.  In Sutherland v. Ernst & Young and Raniere v. Citigroup, Inc. the Second Circuit held that the Federal Arbitration Act (FAA) requires courts to enforce a valid agreement to arbitrate even where the relevant substantive law – here, the Fair Labor Standards Act (FLSA) – permits enforcement via collective or class action.