Unfortunately, more recent jurisprudence in the U.S. has been chipping away at the scrutiny given to contracts of adhesion. In overturning a California Supreme Court decision that greatly restricted arbitration agreements when they were made in the form of contracts of adhesion, Scalia (writing for the court) noted that "the times in which consumer contracts were anything other than adhesive are long past", so California's rule being limited to contracts of adhesion was in practice so broad that it invalidated most arbitration agreements, and therefore interfered with the Federal Arbitration Act (AT&T Mobility v. Concepcion, 2011).