Opponents of payday lending worry that a recent Supreme Court decision has removed class-action lawsuits from their arsenal. In the April 2011 case AT&T Mobility v. Concepcion, the Supreme Court upheld the ability of cellular service providers to insert fine-print provisions banning participation in class-action lawsuits into their contracts with customers. Payday lenders often use similar clauses to evade class-action suits. Before the Supreme Court Ruling, lower courts in North Carolina and California ruled those provisions unlawful. In North Carolina, that ruling allowed for a class-action suit that resulted in a $37.5 million settlement. Advocates worry that such victories are no longer possible as class-action bans force more compaints into individual arbitration.