Jeski v. American Express Co
In Jeski v. American Express Co., 147 Ariz. 19, 708 P.2d 110 (App. 1985), language in the personnel manual providing that employment "can be terminated at any time by either the Company or yourself," 147 Ariz. at 20, 708 P.2d at 111, was arguably inconsistent with other language in the manual "purporting to make a number of assurances of fair treatment, personal respect, and significantly, job security." Id. at 22, 708 P.2d at 113.
The Court held that whether the personnel manual could reasonably be construed to have modified the employment-at-will relationship was a jury question. Id.