Together with the 2011 decision in AT&T Mobility LLC v. Concepción, Dukes may signal a growing Supreme Court hostility toward class actions. 108 AT&T Mobility held that the Federal Arbitration Act preempts a California state rule finding class arbi - tration waivers in consumer contracts to be unconscionable, and thus unenforceable, under certain circumstances. 109 Critics have decried both cases as excessively pro-business. 110