Kesoli v. Anderson Security Agency

A security company supervisor shouted at his subordinates and was terminated by his employer. We conclude that, under the circumstances, the supervisor’s conduct constitutes “harassment,” and therefore “just cause” for termination. We therefore reverse the Navajo Nation Labor Commission (Commission).

I

Appellee Leland Kesoli (Kesoli), a Sergeant Security Guard for Appellant Anderson Security (Anderson), supervised other security guards. At least three of these guards complained to Anderson that Kesoli had shouted at them.1 Kesoli testified before the Commission that he confronted the guards in…