Duncan v. St. Joseph's Hospital & Medical Center
In Duncan v. St. Joseph's Hospital & Medical Center, 183 Ariz. 349, 354, 903 P.2d 1107, 1112 (App. 1995), the employee handbook contained unambiguous language that Duncan's employment was terminable at will, 8 but also contained statements regarding job security and explained a "Performance Improvement Program" that guided supervisors in dealing with employee performance problems.
The Court held that the handbook was not part of Duncan's employment contract because "reasonable persons could not find that the hospital's employee handbook . . . instilled in Duncan any sensible expectations of job security or the belief that she could only be terminated for cause." Id. at 356, 903 P.2d at 1114.