He gave the department 21 years – they gave him no hearing, no case file, and no appeal
A fired Arizona police commander is forcing courts to answer a question every public-sector HR leader should be watching closely.
On April 3, 2026, the United States Court of Appeals for the Ninth Circuit certified three questions to the Arizona Supreme Court in a case that could determine whether changes to state employment protection laws can reach back and undo at-will agreements that were perfectly lawful when they were signed.
Brian Blunt spent roughly 21 years with the Town of Gilbert Police Department, working his way up from patrol officer to detective to sergeant to lieutenant. In 2021, the Town promoted him to police commander. With that promotion came an employment agreement. The agreement classified Blunt as an at-will employee, meaning either side could end the relationship at any time, with or without cause or notice.
Two years later, the Town conducted an employee engagement survey. What followed was an outside human resources firm being brought in to investigate feedback about Blunt. By May 2023, the Town had notified him that it was looking into allegations that he had made unprofessional, offensive, and harassing statements to other employees. Blunt reportedly agreed to sit for an interview with the investigator, but only if he could review the underlying materials first. The Town declined, and the interview never happened.
The Town terminated Blunt in September 2023. According to the court's order, neither the Chief of Police nor the Human Resources Executive Director gave Blunt an opportunity to respond to the reasons behind his firing. The Town also did not provide him with a copy of the investigation or offer any appeal process.
What turns this from a straightforward termination dispute into something far more consequential for HR professionals is the legal question sitting underneath it.
When Arizona first enacted the Peace Officers Bill of Rights in 2014, the statute allowed law enforcement agencies and their officers to enter into employment contracts that could deviate from its protections. At-will agreements were fair game. In 2022, however, the legislature amended that provision. The new language established the statute as a floor of minimum rights and only permitted agreements that go above and beyond those protections. Agreements that fall short, including at-will arrangements, arguably no longer pass muster under the revised law.
Blunt's position is that the 2022 amendment rendered his at-will agreement unenforceable. He argues this is not a case of applying a law retroactively because everything that led to his termination happened after the amendment took effect. The Town sees it differently, maintaining that the amendment cannot reach back to invalidate a contract signed before the law changed and that doing so would violate constitutional protections against the impairment of contracts.
The district court sided with the Town and dismissed the case entirely, finding that the presumption against retroactivity under Arizona law blocked Blunt's central claims. The Ninth Circuit, however, found the questions significant enough and unsettled enough to send them to the Arizona Supreme Court for guidance.
The three certified questions ask whether the presumption against retroactivity bars the amendment from applying to pre-existing at-will agreements, whether the amendment voids those agreements when the triggering events occurred after the law changed, and whether voiding such an agreement would violate the Contract Clause of the Arizona Constitution.
The Ninth Circuit has stayed all proceedings while it waits for the Arizona Supreme Court to respond. No Arizona appellate court has issued a binding decision on these questions.
For HR professionals in the public sector, the stakes are real. The answer could affect how agencies across Arizona structure employment agreements going forward and whether existing at-will contracts with law enforcement officers remain enforceable. It is also a reminder that when legislatures expand employee protections, the ripple effects can reach agreements that were signed well before the ink dried on the new law.
