Millions of parties enter into arbitration agreements each year, and those parties expect courts to honor those agreements. Congress enacted the Federal Arbitration Act (FAA) to protect this very freedom of contract. And the Supreme Court has consistently reaffirmed that arbitration is a matter of consent, and that private agreements to arbitrate should be enforced according to their terms. Plaintiffs' attorneys, on the other hand, hate arbitration agreements because they deprive them of having contingency fee clients. Resolution under mandatory arbitration is often swifter than trials, and plaintiffs' attorneys often get little or no money out of them. The National Labor Relations Board (NLRB) recently ruled against home builder D.R. Horton, holding that a class action waiver was unenforceable under the National Labor Relations Act (NLRA). At issue was D.R. Horton's mutual arbitration agreement and class action waiver that the company entered into with its employees.