§ 6.1.6 Sources of Public Policy. The court in Wagenseller indicated that in Arizona,90 wrongful discharge claims could be premised upon "public policy articulated by constitutional, statutory or decisional law."91 However, the EPA purported to eliminate state decisional law, federal statutes and municipal codes as potential sources of public policy that would support a wrongful discharge claim.92 Prior to the enactment of the EPA, decisional law clearly was a potential source of public policy in Arizona,93 municipal codes apparently were not,94 and the issue of whether a federal statute could support a state law wrongful discharge claim was an open question.95
In Picht v. Peoria Unified School District No. 11, an Arizona federal district court judge indicated that the termination of a school administrator's employment in violation of a school district policy is not actionable because the EPA does not prohibit terminations in violation "of public or other policies not set forth in a statute."96
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